DSJ Group

    Whistleblowing Policy

    1. Introduction

    DSJ Group is committed to maintaining high ethical standards in all its operations and expects all employees, contractors, and third parties to act with integrity. This Whistleblowing Policy (the "Policy") aims to encourage and support individuals in raising concerns about any wrongdoing, misconduct, or illegal activities within the company. The Policy ensures that individuals who report concerns in good faith will be protected from retaliation.

    2. Purpose of the Policy

    The purpose of this Policy is to:

    • Provide a clear and confidential process for employees, contractors, and third parties to report concerns about potential wrongdoing.
    • Protect whistleblowers from retaliation or victimization for reporting concerns in good faith.
    • Ensure that all concerns are investigated thoroughly and appropriate actions are taken.

    3. Scope of the Policy

    This Policy applies to all employees, officers, directors, contractors, subcontractors, consultants, suppliers, and any third parties who work with or for DSJ Group.

    4. What Can Be Reported?

    Whistleblowing concerns can relate to a wide range of issues, including, but not limited to:

    • Criminal activity: Fraud, theft, bribery, corruption, or any other illegal conduct.
    • Financial misconduct: Accounting irregularities, financial misreporting, or misuse of funds.
    • Health & Safety violations: Unsafe working conditions or failure to comply with health and safety regulations.
    • Environmental violations: Environmental damage or non-compliance with environmental regulations.
    • Harassment and discrimination: Any form of workplace bullying, harassment, or unlawful discrimination.
    • Unethical conduct: Unethical behavior, conflicts of interest, or violations of the company's policies.
    • Mismanagement: Serious mismanagement or unethical business practices that put the company's reputation or financial stability at risk.

    5. Reporting Concerns

    If you have a concern or suspect that wrongdoing is taking place within the company, you should report it as soon as possible. Concerns can be raised through the following channels:

    • Line manager: If you feel comfortable, you may report your concern to your immediate supervisor.
    • HR department: If you prefer, you can contact the HR department to report the issue.
    • Whistleblowing hotline: DSJ Group provides a confidential whistleblowing hotline for reporting concerns anonymously.
    • Email or online portal: Concerns can also be reported via our dedicated whistleblowing email address.

    Concerns can be raised anonymously if desired. However, it is recommended that you provide your contact details in case further information or clarification is needed during the investigation.

    6. Protection for Whistleblowers

    DSJ Group is committed to protecting individuals who report concerns in good faith from retaliation or victimization. Protection includes:

    • Confidentiality: The identity of the whistleblower will be kept confidential unless disclosure is required by law or necessary for the investigation.
    • No retaliation: DSJ Group will not tolerate retaliation against any individual who raises a concern in good faith. Retaliation could include dismissal, disciplinary action, harassment, or discrimination.
    • Support: The company will provide support to whistleblowers during the investigation process and ensure that they are not subject to unfair treatment.

    If any employee feels they have been subjected to retaliation, they should report it immediately, and the company will investigate the matter thoroughly.

    7. Investigation Process

    Once a concern has been reported, DSJ Group will ensure that it is investigated promptly and thoroughly. The investigation process will include:

    • Acknowledging receipt of the concern.
    • Assessing the severity and credibility of the concern raised.
    • Assigning an appropriate investigator or team to conduct the investigation.
    • Keeping the whistleblower informed of the progress and outcome of the investigation (if they are identified).
    • Taking appropriate action, if necessary, based on the findings of the investigation.

    All investigations will be conducted fairly and without prejudice, respecting the rights of all parties involved.

    8. False or Malicious Allegations

    While DSJ Group encourages the reporting of concerns in good faith, it is important to understand that making false or malicious allegations is not acceptable. Any individual found to have made a false or malicious report may face disciplinary action. However, individuals reporting concerns in good faith, even if the outcome does not support their concern, will be protected from retaliation.

    9. Responsibilities

    • Employees: Employees are encouraged to report any concerns they have regarding misconduct, unethical behavior, or violations of company policies. They must cooperate with investigations and follow the reporting procedures outlined in this Policy.
    • Managers and Supervisors: Managers and supervisors are responsible for fostering a culture of openness and transparency, encouraging employees to report concerns, and ensuring that any reports of wrongdoing are treated seriously and appropriately.
    • HR and Compliance Team: HR and the compliance team are responsible for handling and investigating reports of wrongdoing, ensuring that investigations are conducted in a timely and fair manner, and providing support to whistleblowers.

    10. Monitoring and Review

    This Policy will be regularly reviewed and updated to ensure it remains effective and in compliance with current laws and regulations. DSJ Group will monitor the effectiveness of the whistleblowing process and track the outcomes of reported concerns.

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