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Whistleblower Policy

Last Updated: 1st September 2024

Sen & Ray LLC-FZ ("the Company") is committed to maintaining a culture of transparency, accountability, and ethical behavior. This Whistleblower Policy provides a framework for employees, contractors, suppliers, and other stakeholders to report concerns about unethical, illegal, or improper conduct within the Company. It ensures that all disclosures are handled confidentially, professionally, and without fear of retaliation.

Scope

This policy applies to all employees, officers, contractors, suppliers, and third parties associated with Sen & Ray LLC-FZ. It covers concerns related to:

  • Fraud, corruption, or financial misconduct.
  • Breaches of laws or regulations.
  • Breaches of the Company’s Code of Conduct or policies.
  • Modern slavery, human trafficking, or labor law violations.
  • Discrimination, harassment, or abuse of authority.
  • Health, safety, and environmental violations.
  • Any activity that poses a risk to the Company’s reputation or integrity.

Policy Statement

Sen & Ray LLC-FZ encourages individuals to report any concerns of wrongdoing in good faith. The Company guarantees:

  • Confidentiality: The identity of whistleblowers will be protected to the fullest extent possible.
  • Non-Retaliation: No whistleblower will face retaliation, discrimination, or adverse consequences for raising a concern in good faith.
  • Fair Investigation: All reports will be investigated thoroughly, fairly, and promptly.

Reporting Concerns

  1. How to Report:
    Concerns can be reported through the following channels:
    • Email: whistleblower@senandray.ae
    • Mail: Addressed to the Compliance Officer, Sen & Ray LLC-FZ, Level 41, Emirates Towers, Sheikh Zayed Road, PO BOX 31303, Dubai, UAE.
  2. Anonymous Reporting:
    Whistleblowers may choose to report anonymously. However, anonymity may limit the ability to conduct a comprehensive investigation.
  3. Details to Provide:
    • A description of the concern.
    • Names of individuals involved (if known).
    • Dates, locations, and supporting evidence (if available).

Handling of Reports

  1. Acknowledgment:
    Reports will be acknowledged within 5 business days, where contact details are provided.
  2. Investigation:
    • The Compliance Officer or a designated investigator will assess and investigate the concern.
    • Investigations will be conducted impartially and in a timely manner.
  3. Outcomes:
    • If misconduct is confirmed, appropriate corrective action will be taken, which may include disciplinary action, legal reporting, or policy changes.
    • Whistleblowers will be informed of the outcome where appropriate and lawful.

Protection for Whistleblowers

  1. Non-Retaliation:
    • Retaliation, harassment, or discrimination against whistleblowers is strictly prohibited.
    • Any individual found retaliating against a whistleblower will face disciplinary action, up to and including termination.
  2. False Reporting:
    • Reports made in good faith are protected under this policy, even if they are not substantiated.
    • However, knowingly making false or malicious reports is a serious violation and may result in disciplinary action.

Training and Awareness

  1. Employee Training:
    • All employees will receive training on this policy as part of their onboarding process.
    • Refresher training will be conducted annually.
  2. Awareness Campaigns:
    • Periodic campaigns will remind employees and stakeholders of their rights and responsibilities under this policy.

Monitoring and Review

  1. Policy Review:
    • This policy will be reviewed annually or as needed to ensure its effectiveness and alignment with legal requirements.
  2. Reporting Metrics:
    • Summary data on whistleblowing activity (e.g., number of reports, resolution status) will be reported to the Board of Directors, ensuring whistleblower confidentiality.

Approval and Publication

This statement has been approved by the Board of Directors of Sen & Ray LLC-FZ and is reviewed annually to ensure ongoing compliance and relevance. It will be made publicly available on our website and communicated to stakeholders.

Contact Information

For questions about this statement, please contact us at compliance@senandray.ae