Whistleblower Policy

PURPOSE & COMMITMENT

ProClipse Consulting FZ LLC is committed to the highest standards of ethical conduct, integrity, and compliance in all our business activities. This Whistleblower Policy is a crucial component of our commitment to:

• Detect and prevent corrupt, illegal, or undesirable conduct

• Encourage and protect individuals who report wrongdoing

• Maintain a culture of openness, accountability, and continuous improvement

We strongly encourage all stakeholders to speak up about any suspected or witnessed misconduct, assured of our support and protection.

SCOPE

This policy applies to:

• All employees (full-time, part-time, temporary)

• Directors and officers

• Contractors and consultants

• Suppliers and service providers

• Clients and business partners

• Any individual associated with ProClipse Consulting FZ LLC

   

  This policy is applicable across all jurisdictions where ProClipse operates, Regardless if ProClipse Consulting has a legal entity or not.

DEFINITIONS

• Whistleblower: Any individual who reports misconduct or an improper state of affairs under this policy.

• Reportable Conduct: Any conduct that is illegal, unethical, or contrary to ProClipse's policies and values.

• Protected Disclosure: A report made under this policy that qualifies for protection.

• Detrimental Conduct: Any action taken against a whistleblower in retaliation for making a report.

REPORTABLE CONDUCT

Reportable conduct includes, but is not limited to:

• Financial malpractice, impropriety, or fraud

• Failure to comply with legal or regulatory obligations

• Criminal activity

• Bribery or corruption

• Conflicts of interest

• Unethical behavior or serious improper conduct

• Health, safety, or environmental risks

• Discrimination, harassment, or bullying

• Violations of our Diversity, Equity & Inclusion (DEI) policy or practices

• Actions undermining our commitment to equality and inclusivity

• Retaliation against a whistleblower

• Deliberate concealment of any of the above

REPORTING MECHANISM

ProClipse Consulting FZ LLC provides multiple channels for reporting:

• Dedicated whistleblower email: [email protected]

• Online reporting form: Whistleblower Report Form

• Whistleblower hotline: +971 50 469 5694

• In-person report to any member of the Whistleblowing Investigation Committee (WIC)

   

  Our online Whistleblower Report Form provides a structured and secure way to submit detailed information about potential misconduct. The form is designed to gather essential information while protecting the reporter's confidentiality.

   

  Reports can be made anonymously if desired. We encourage providing as much detail as possible to facilitate thorough investigation.

PROTECTION FOR WHISTLEBLOWERS

ProClipse Consulting FZ LLC is committed to protecting whistleblowers. This includes:

• Confidentiality: The identity of the whistleblower will be kept confidential unless disclosure is required by law or necessary for the investigation.

• Non-retaliation: P ProClipse Consulting FZ LLC prohibits any form of retaliation, discrimination, harassment, or victimization against whistleblowers.

• Legal protections: Whistleblowers are entitled to specific protections under applicable laws in the jurisdictions where we operate.

INVESTIGATION PROCESS

1. All reports will be acknowledged within 3 business days.

2. The WIC will assess the report and determine the appropriate course of action.

3. If an investigation is warranted, it will be conducted fairly, objectively, and in a timely manner.

4. The whistleblower will be kept informed of the progress and outcome of the investigation, where appropriate.

5. Investigations will typically be completed within 90 days, unless circumstances require a longer period.

FALSE & MALICIOUS REPORTS

ProClipse Consulting FZ LLC encourages genuine reporting but does not tolerate knowingly false or malicious reports. 

We distinguish between reports made in good faith that prove unfounded and those made with deliberate intent to mislead or cause harm.

• For internal whistleblowers, false reports may result in disciplinary action. 

• For external parties, we reserve the right to take appropriate legal action, including reporting to relevant authorities where applicable.

Any action taken in response to false reports will follow due process, comply with applicable laws in relevant jurisdictions, and only occur after thorough investigation.

We remain committed to protecting genuine whistleblowers and encourage reporting of all legitimate concerns without fear of reprisal.

SUPPORT FOR WHISTLEBLOWERS

ProClipse Consulting FZ LLC will provide support to whistleblowers, including:

• Access to our Employee Assistance Program for counseling

• Legal support where appropriate

• Protection from detrimental conduct

DATA PROTECTION

All personal data collected as part of the whistleblowing process will be handled in accordance with applicable data protection laws and ProClipse's Data Protection Policy.

TRAINING AND AWARENESS

• All employees will receive training on this policy as part of their onboarding.

• Annual refresher training will be provided to all staff.

• The policy will be prominently displayed on our intranet and website.

ROLES AND RESPONSIBILITIES

• Whistleblowing Investigation Committee (WIC): Responsible for receiving, assessing, and investigating reports.

• Chief Compliance Officer: Oversees the whistleblowing program and reports to the Board.

• Managers: Required to report any concerns raised to them and support the whistleblowing process.

• All employees: Responsible for reporting misconduct and cooperating with investigations.

REPORTING TO THE BOARD

The Chief Compliance Officer will provide quarterly reports to the Board on:

• Number and types of reports received

• Investigation outcomes

• Emerging trends or systemic issues

GLOBAL CONSIDERATIONS

This policy complies with whistleblower protection laws in all jurisdictions (where available) and where ProClipse operates. When local laws provide stronger protections, those will apply.

REVIEW AND UPDATES

This policy will be reviewed annually by the Chief Compliance Officer and updated as necessary to ensure ongoing effectiveness and compliance with changing regulations. Last updated on 15 August 2024 & Approved by: Managing Partner.

Compliance with this policy is mandatory. Breaches may result in disciplinary action, up to and including termination of employment or business relationships.

For any questions or concerns about this policy, Contact: 

Chief Compliance Officer

PO Box 413724, Dubai, United Arab Emirates

[email protected]

Tel: +971 56 6673300

“ProClipse: Change Is Good” is the exclusively dedicated Change Management brand and is owned and operated by ProClipse Consulting FZ LLC.