1. Purpose
Ethical Trade Services Africa (ETSA) is committed to maintaining the highest standards of ethics, integrity, and transparency. This Whistleblower Policy aims to encourage employees, contractors, partners, and other stakeholders to report concerns regarding unethical behavior, misconduct, or violations of laws, policies, or regulations. The policy also ensures protection against retaliation for those who report such concerns in good faith.
2. Scope
This policy applies to all ETSA employees, directors, contractors, consultants, vendors, and any third party engaged in ETSA’s operations. The policy covers:
- Fraudulent activities.
- Harassment, discrimination, or workplace misconduct.
- Violations of company policies, laws, or regulations.
- Mismanagement or abuse of company resources.
- Risks to public safety or the environment.
3. Reporting Mechanisms
3.1 Channels for Reporting
ETSA provides multiple secure channels for reporting concerns:
- Dedicated Email: whistleblower@ethicaltradeservices.co.ke
- Online Reporting Portal: Accessible via ETSA’s website.
- Confidential Hotline: +: +254 768 639 774 .
- Direct Reporting to Ethics Committee: Concerns may be reported to the Ethics Committee Chairperson.
3.2 Anonymous Reporting
ETSA recognizes the importance of anonymity and allows individuals to report concerns without revealing their identity. Reports can be submitted anonymously via the online reporting portal or confidential hotline.
4. Confidentiality
All reports will be handled with strict confidentiality to the maximum extent permissible by law. Information about the whistleblower and the reported concern will only be disclosed to those directly involved in investigating or addressing the issue.
5. Protection Against Retaliation
ETSA strictly prohibits retaliation against individuals who report concerns in good faith. Retaliation includes but is not limited to:
- Dismissal or demotion.
- Harassment or intimidation.
- Any form of discrimination.
Whistleblowers who experience retaliation are encouraged to report it through the established channels. Retaliators will face disciplinary action, up to and including termination of employment or contract.
6. Investigation Process
6.1 Acknowledgment of Reports
Upon receiving a report, ETSA will acknowledge receipt within five business days (except for anonymous reports).
6.2 Preliminary Review
The Ethics Committee will conduct a preliminary review to determine the credibility and scope of the report.
6.3 Investigation
If the report warrants further action, the Ethics Committee will:
- Assign investigators with appropriate expertise and independence.
- Collect and analyze relevant evidence.
- Conduct interviews with involved parties.
6.4 Resolution and Follow-Up
Based on the investigation findings, appropriate actions will be taken, which may include:
- Disciplinary action against individuals found guilty of misconduct.
- Policy or procedural improvements.
- Communication of investigation outcomes to the whistleblower, where appropriate.
7. False or Malicious Reporting
ETSA encourages good faith reporting. However, intentionally false or malicious reports are a violation of this policy and may result in disciplinary action against the reporter.
8. Record Keeping
All reports, investigations, and resolutions will be documented and securely stored. Access will be limited to authorized personnel to maintain confidentiality and compliance with applicable laws.
9. Policy Review and Updates
This policy will be reviewed annually by the Ethics Committee to ensure its effectiveness and alignment with legal or regulatory changes. Amendments, if any, will be communicated to all stakeholders.
