ERINYS IRAQ LIMITED

WHISTLEBLOWING POLICY

Version 9 - 01 Oct 2023

1         Introduction

Erinys Iraq Limited is committed to upholding the highest standards of integrity, ethics, and accountability in all aspects of its operations. As part of this commitment, we have implemented a comprehensive Whistleblowing Policy to provide a safe and confidential avenue for our employees, contractors, sub-contractors, consultants, temporary staff, vendors, suppliers, clients, any other stakeholders, and any member of the public to report any concerns or wrongdoing they may encounter within our organization. This policy underscores our dedication to fostering a culture of transparency and trust, ensuring that all individuals associated with Erinys Iraq Limited can speak up without fear of retaliation, and contribute to the maintenance of our ethical and legal standards.

2         Policy Statement

Erinys Iraq Limited is dedicated to maintaining the highest standards of ethical conduct, transparency, and corporate governance throughout its operations. We firmly believe in the importance of fostering an environment where all stakeholders can raise concerns and report potential wrongdoing without fear of reprisal. Our Whistleblowing Policy is designed to provide a confidential and secure mechanism for reporting any actions or behaviours that violate our ethical, legal, or regulatory standards. We are committed to thoroughly and impartially investigating all reports and taking appropriate corrective actions as necessary. This policy reaffirms our commitment to accountability, integrity, and the well-being of our employees, contractors, sub-contractors, consultants, temporary staff, vendors, suppliers, clients, any other stakeholders, and the communities we serve.

3         Scope

This Whistleblowing Policy process for employees, contractors, sub-contractors, consultants, temporary staff, vendors, suppliers, clients, any other stakeholders, and any member of the public.

4         Objective and Intent

The objective of Erinys Iraq Limited's Whistleblowing Policy is to establish a robust framework that encourages and enables individuals associated with our organization to report concerns, misconduct, or violations of our ethical and legal standards. Our intent is to create a culture of transparency, integrity, and accountability where all stakeholders feel empowered to come forward with information about any wrongdoing, free from fear of retaliation. We are committed to promptly and impartially investigating all reports, taking appropriate actions, and ensuring the confidentiality of whistleblowers to maintain the highest standards of corporate governance, ethics, and compliance within our operations.

5         Policy Directives

Erinys is unwavering in its commitment to upholding ethical and transparent standards in all interactions with its diverse range of stakeholders. The Company places paramount importance on fostering an environment where employees, contractors, consultants, temporary staff, sub-contractors, vendors, suppliers (collectively referred to as "Stakeholders"), clients, and members of the public are encouraged to voice concerns related to risks, malpractice, or wrongdoing that may impact others, including Erinys staff, visitors, clients, and suppliers. It is essential to note that these concerns can be raised without the fear of facing any form of retribution, such as victimization, harassment, or disciplinary action, if they are communicated in good faith and without malicious intent.

5.1. Overview 

  • This policy encompasses a broad spectrum of actions, including those that could potentially be illegal, contravene established policies, tarnish the Company's reputation, or create conflicts of interest. Concerns may encompass, but are not limited to:
  • Violations of Human Rights.
  • Acts that are in breach of the law.
  • Instances of gross misconduct.
  • Any deviation from Standard Operating Procedures (SOPs) that may jeopardize the safety of others.
  • Deliberate damage to property or harm to the environment.
  • Engagement in bribery, fraud, or any other form of corruption.

It is important to note that Erinys has established alternative procedures available to its employees, such as the Grievance Policy IMS-ER-P-001, which specifically addresses employment-related complaints.

5.2. Reporting Concerns

Ø  Internal Reporting

In the initial phase, the Protected Person should report their concerns internally to their immediate supervisor. However, if there are sensitivities or concerns related to this supervisor regarding the issue at hand, the initial report should be directed to the next level of management or submitted via the dedicated whistleblowing email: [email protected] . While the initial report may be conveyed verbally, after discussing the matter with a manager, the Protected Person must submit a formal written report with the subject title "WHISTLEBLOWING." This written report should contain comprehensive details of the observed or suspected misconduct, including information about the individuals involved, the date(s), and location(s) of the incident(s). The option to maintain anonymity is available, but it is essential that the receiving manager acknowledges the receipt of the report. Management must be promptly informed of any such reports, and an independent investigator shall be appointed to investigate the matter. Those making a whistleblowing report must:

  • Disclose the information in good faith, believing it to be substantially true.
  • NOT make any false allegations.

The reason for the above is because only whistleblowers making reports in good faith will be accorded protection; abuse of the Whistleblower Protection Policy may result in disciplinary action.

Ø  External Reporting

If a Protected Person deems internal reporting to be an inadequate course of action due to concerns such as the fear of retaliation or the possibility of their report being disregarded, they retain the option to escalate their report to an external authority. It is important to note that the same considerations outlined in the Confidentiality, Resolution and Review paragraphs remain applicable. 

Ø  Confidentiality

All concerns will be handled with the utmost confidentiality. This policy strongly encourages individuals to include their name and position when reporting concerns, whenever feasible. It is crucial to note that in cases where an anonymous complaint has been submitted, a comprehensive investigation cannot be guaranteed, as obstacles may arise in obtaining complete information. It is essential to emphasize the following:

  • Employees/Contractors are expected to disclose information in good faith.
  • Employees/Contractors should have a substantial belief in the truthfulness of their report.
  • Employees/Contractors must refrain from making unfounded allegations.
  • Reporting must be confined to genuine concerns, as any misuse or abuse of the Whistleblower Protection Policy and Procedure may result in disciplinary actions.

Every effort will be exerted to maintain the confidentiality of individuals, raising concerns until such time as a formal investigation is initiated. Nevertheless, there may be circumstances wherein, due to the nature of the investigation, it becomes necessary to reveal the identity of the complainant. Such instances may arise in connection with related disciplinary or legal inquiries or proceedings. The Erinys Representative will make diligent efforts to notify the individual when the likelihood of their identity being disclosed exists.

Ø  Investigations

Erinys is dedicated to conducting investigations of disclosures in a manner that upholds principles of fairness, expediency, and confidentiality.

Upon the appointment of an investigator, the investigator shall receive a copy of the report and proceed to interview both the Protected Person and the manager who raised the concern. The investigator's primary responsibility is to ascertain the facts surrounding the case and determine whether any illegal or unethical actions, or violations of SOPs/certified standards, have occurred. The following guidelines must be rigorously adhered to:

  • Timely Initiation and Fair Conduct: Investigations are to be initiated promptly, carried out impartially, and completed in the shortest feasible time frame.
  • Paramount Confidentiality: Maintaining confidentiality regarding the source of the report and the individual under scrutiny is of utmost importance throughout the investigation process.
  • Thorough Gathering of Evidence: The investigator must diligently gather evidence to the fullest extent feasible. This includes obtaining relevant documents, conducting interviews with individuals under scrutiny as well as potential witnesses, and keeping appropriate records. Observations should also be documented.
  • Notification and Opportunity for Explanation: Individuals implicated in the report must be promptly informed of the allegations against them and afforded the opportunity to provide their explanations or refutations. These explanations should be comprehensively documented within the report. Additionally, they must be informed of the investigation's outcome, particularly any adverse comments included in the report, prior to its finalization.
  • Evidence-Based Conclusions: The investigator's report should include an analysis of the facts, supported by evidence, and draw conclusions regarding the substantiation or dismissal of the whistleblowing allegations. It is not within the investigator's purview to make recommendations concerning corrective or disciplinary actions that may be warranted.
  • Clear Documentation of Unfounded Allegations: In cases where the investigator determines that the allegations are unfounded or lacks sufficient evidence to support them, the report must explicitly articulate these findings. The importance of maintaining confidentiality is amplified in such cases, with a particular emphasis on safeguarding the identities of those involved, especially the whistleblower and the implicated parties.

Erinys remains steadfast in its commitment to safeguarding the confidentiality and integrity of the investigative process, ensuring that it adheres to the highest standards of transparency and fairness.

5.3. Follow-up Action

Following the completion of the investigator's report, it is to be presented to the Country Director (CD), who will determine the necessary follow-up actions, seeking legal counsel as needed.

Ø  Stringent Confidentiality: All whistleblowing reports, including those submitted by the whistleblower and the investigator, are to be treated with the utmost confidentiality. Their distribution shall be closely controlled, and their storage and access shall adhere to stringent restrictions. This is especially crucial in cases where reports are ultimately found to be unfounded.

Ø  Substantiated Reports: When a whistleblowing report is validated, the MD may opt to initiate further investigation to uncover the root causes of the issue. This step aims to facilitate the development of appropriate corrective measures that can mitigate the risk of recurrence.

Ø  Disciplinary Action: It is highly likely that disciplinary actions will be taken because of substantiated reports. The specific actions will be determined on a case-by-case basis, but it should be noted that severe misconduct, may lead to immediate dismissals.

In summary, the primary outcomes of this process encompass disciplinary actions and the formulation of a corrective action plan designed to enhance processes and procedures, thereby minimizing the potential for future occurrences.

5.4. Confidentiality

Confidentiality has emerged as a pervasive and prominent theme throughout this policy and its associated procedures. Its profound significance cannot be overstated, as breaches of confidentiality have the potential to undermine the efficacy of this policy, as they may deter potential whistleblowers from fulfilling their duty to report. Therefore, every conceivable effort must be undertaken to safeguard confidentiality until the initiation of a formal investigation. This commitment to confidentiality serves to protect not only the whistleblower but also those individuals implicated and the overall reputation of the Company.

While it is imperative to maintain confidentiality, there may arise circumstances during an investigation where it becomes necessary to reveal the identity of the whistleblower. Such instances may arise due to legal obligations or other compelling factors. In such situations, Erinys management is responsible for keeping those individuals who may be affected by the disclosure informed and well-informed of the rationale behind such actions.

5.5. Resolution and Record Management

At the conclusion of the investigation, the Investigator will furnish Senior Management with a comprehensive analysis and recommend procedural adjustments aimed at mitigating the likelihood of future occurrences.

The proper handling, retention, and storage of records constitute a fundamental aspect of the Whistleblower Procedure, and access to these records must be subject to stringent restrictions.

6         Review and Continuous Improvement

At Erinys Iraq Limited, our commitment to transparency and ethical conduct remains unwavering. We recognize the importance of continuously enhancing our Whistleblowing Policy to ensure its effectiveness and alignment with evolving best practices. To this end, we engage in regular reviews of our policy and procedures, incorporating feedback from stakeholders, monitoring its implementation, and staying abreast of legal and regulatory developments. By fostering a culture of continuous improvement, we reaffirm our dedication to providing a secure and confidential avenue for reporting concerns, thereby strengthening our commitment to ethical behaviour and corporate responsibility.

7         Conclusion

Erinys Iraq Limited's Whistleblowing Policy underscores our unwavering commitment to ethical conduct, transparency, and accountability. We firmly believe that providing a safe and confidential mechanism for reporting concerns is not only a corporate responsibility but also a crucial element in maintaining trust, integrity, and the highest standards of corporate governance. Through this policy, we demonstrate our dedication to fostering an environment where individuals can speak up without fear, confident that their voices will be heard, and that appropriate actions will be taken. Together, we build a stronger, more ethical organization that upholds the values we hold dear.