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HHI WHISTLEBLOWING POLICY

I. Background, Scope and Purpose

1. HHI is committed to the highest standard of conduct and ethical behavior in its programme
activities and related processes with the aim to promoting and supporting a culture of corporate
compliance, honest and ethical behavior and individual and corporative accountability,
particularly towards children and communities in need that we serve.

2. HHI encourages the safe and confidential reporting of suspected unethical, illegal, fraudulent,
corrupt or dishonest conduct and shall ensure that those who promptly report may do so with
confidence and without fear of intimidation, ramifications or adverse consequences.

3. This Whistleblowing Policy relates to the protection of those ‘speaking-up’ about misconduct
(also known as "whistleblowers") and how HHI will respond to reports of misconduct.

4. All HHI members are aware of this whistle blowing policy available on our external website and
of established safe and confidential reporting mechanisms.

5. HHI will periodically review this Policy to ensure that it is operating effectively, and may amend
this Policy from time to time at its discretion.

Policy Access

A copy of this Policy is accessible to, amongst others, all employees and officers of HHI via
Our external website:mmicentralafricanprovince.in.

2. Making a disclosure
What matters should be reported under this Policy?

1. HHI encourages safe and confidential reporting of suspected dishonest, corrupt, fraudulent or
unlawful conduct or practices, including bribery; financial irregularities; unfair, dishonest or
unethical dealings with a customer or third party; unethical or serious improper conduct including
breaches of any legal or regulatory obligations, breaches of HHI or engaging in misleading or
deceptive conduct especially in relation to accounting or financial reporting practices; any other
serious impropriety; or any other conduct or act which causes, or has the potential to cause, loss
or liability to HHI or which may otherwise be detrimental to HHI interests (including, for
example, unsafe work practices or abuse of HHI resources.
2. Any (perceived) form of retaliation affecting employee, This may include but is not limited to : a
decision about employment, transfer or promotion; a decision about the terms and conditions of
employment of the whistleblower; or a decision to suspend or terminate the employment of the
whistleblower, or otherwise to discipline the whistleblower.
3. It includes information about misconduct, or the information about misconduct includes or is
accompanied by a personal work-related grievance (i.e. a mixed report); the matter relates to
misconduct, or breaches of employment or other laws punishable by imprisonment for a period of
12 months or more; it relates to conduct that represents a danger to the public, or the disclosure
relates to information that suggests misconduct beyond the whistleblower's personal
circumstances; the whistleblower suffers from or is threatened with detriment for making a
disclosure; or the whistleblower is seeking legal advice .

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