The purpose of the Willshir Whistle-blower Policy is to provide a mechanism for employees, customers, vendors, and other stakeholders to report any concerns or potential violations of ethical, legal, or regulatory standards by the employees, officers, directors or agents of the company or its affiliates.

This policy encourages open communication and transparency, protects whistle-blowers from retaliation or discrimination, and ensures that all concerns are promptly and thoroughly investigated. Furthermore, this policy aims to promote a culture of integrity, accountability and compliance within Willshir and strengthen the company’s commitment to ethical behaviour and responsible corporate citizenship.

This policy applies to all employees, vendors, customers and affiliates of Willshir globally. All stakeholders must read, understand, and comply with this policy and raise any concerns or questions related to potential violations of ethical, legal, or regulatory standards.

Policy Statement

The Policy Statement for the Willshir Whistle Blower Policy asserts our commitment to promoting a work environment that encourages open communication, transparency, and compliance with ethical standards and regulatory requirements. We recognise that reporting concerns about potential violations of laws, regulations, or company policies may be difficult, and we value and support those who come forward to report such concerns in good faith.

Willshir is committed to protecting whistle-blowers from retaliation, harassment, discrimination, or any adverse actions that may affect their employment, compensation, or terms of engagement. Employees who report potential violations of laws, regulations, or company policies will be protected from any form of retaliation or punishment, provided that their reports are made in good faith and without malice.

Exceptions to the policy include any reports that are knowingly false or made with malicious intent. Additionally, employees who make false reports can be subject to disciplinary actions, including termination of employment where appropriate.

The Policy also states that all reports will be handled with confidentiality, and information will only be shared with the relevant parties on a “need-to-know” basis. Every report will be thoroughly, and impartially investigated, and corrective action will be taken where applicable.

We aim to promote integrity, transparency, and accountability by implementing this policy. We strongly encourage all employees to report any concerns relating to actual or potential breaches of laws, regulations, or company policies. Willshir is committed to ensuring that all whistle-blowers are protected from retaliation and that their concerns are taken seriously and investigated appropriately.


Common terms and phrases used:

  1. Whistle-blower: A person who reports or exposes an illegal or unethical activity within the company.
  2. Retaliation: Any negative action taken against an employee who has reported a violation, including but not limited to, dismissal, demotion, transfer, harassment, intimidation, or discrimination.
  3. Confidential reporting channel: A secure and confidential method, like a hotline, website, or physical mailbox, through which employees can report any concerns or violations without fear of retaliation.
  4. Reportable violation: Any illegal, unethical, or inappropriate behaviour that does or may harm the company, including but not limited to fraud, bribery, harassment, discrimination, and safety breaches.
  5. Investigation: The process of verifying the facts of a reported violation, collecting evidence, and reviewing the information to determine if a violation has occurred.
  6. Compliance Officer: The designated person or team responsible for receiving and investigating reports of violations. They are also responsible for implementing and maintaining the whistle-blower policies, procedures, and training.
  7. Anonymous Reporting: A reporting mechanism where whistle-blowers can submit their reports without providing their identity.


Entities responsible for implementing, maintaining, and enforcing the policy:

  1. Board of Directors: The Board of Directors is responsible for approving the Whistle-blower Policy and ensuring that it is implemented in an effective and transparent manner.
  2. Senior Management Team: The Senior Management Team is responsible for communicating the policy to employees, ensuring that employees have access to the policy, and providing necessary training and guidance to employees on how to report complaints or concerns.
  3. Employees: All employees are responsible for complying with the Whistle-blower Policy and reporting any concerns or complaints promptly and appropriately.
  4. Whistle-blower Coordinator: The Whistle-blower Coordinator is responsible for receiving all complaints and concerns related to the policy, ensuring that all reports are appropriately reviewed and investigated, and providing timely updates and feedback to the whistle-blower.
  5. Legal and Compliance Departments: The Legal and Compliance Departments are responsible for ensuring that all complaints and concerns are investigated promptly and that appropriate measures are taken to protect whistle-blowers from retaliation.
  6. Human Resources Department: The Human Resources Department is responsible for ensuring that employees are aware of the protection offered to whistle-blowers and that whistle-blowers are not retaliated against for making a complaint or raising a concern.

All stakeholders in the organisation are responsible for promoting an ethical culture that supports whistle-blowers and encourages reporting any concerns or complaints.


  1. Reporting: Any employee who wishes to make a report under this Whistle Blower Policy can do so by contacting the designated Whistle Blower Officer via the dedicated communication channel.
  2. Confidentiality: All reports received under this policy will be treated with utmost confidentiality. Willshir will not reveal the identity of the whistle-blower unless required by law or necessary for investigations.
  3. Investigation: The Whistle Blower Officer will conduct a preliminary review of the report and determine the appropriate investigation response. Willshir will investigate all complaints received under this policy.
  4. Response: Within a reasonable period, the Whistle Blower Officer will provide feedback to the whistle-blower regarding the status of the investigation, including the expected timeline for completion and any follow-up actions.
  5. Protection: Willshir will protect all whistle-blowers from retaliation, discrimination, or adverse employment actions as a result of their good-faith report. Any employee found to have retaliated against a whistle-blower will be subject to disciplinary action.
  6. False Reports: Any employee found to have made a false or malicious report under this policy will be subject to disciplinary action, up to and including termination.
  7. Retention: Willshir will maintain complete and accurate records of all reports received under this policy, investigations conducted, and any actions taken as a result.
  8. Exceptions: Any exceptions to this policy must be approved in advance by the CEO.

Disciplinary Actions

Willshir takes all allegations of retaliatory conduct against whistle-blowers seriously. Any employee found to have engaged in such conduct will be subject to disciplinary action, up to and including termination of employment. In addition, Willshir may take disciplinary action against any employee who violates this policy or who otherwise engages in conduct that is determined to be contrary to the best interests of the company, its customers, and/or its employees.

Disciplinary actions may include but are not limited to:

  1. Verbal or written warning
  2. Suspension from work
  3. Demotion
  4. Reduction in pay
  5. Termination of employment
  6. Legal action

Willshir will investigate all reports of retaliation or other violations of this policy, and appropriate corrective action will be taken as necessary. In doing so, Willshir will protect the confidentiality of the whistle-blower to the extent possible, consistent with legal requirements and the need to conduct an effective investigation.


The following measures will be taken:

  1. Communication: Willshir will communicate the policy to all employees through various communication channels, including email, intranet, and training sessions. The employee handbook and any new-hire training will also include the policy.
  2. Training: All employees, particularly those in positions with a higher risk of exposure to illegal or unethical activities, will receive training on the policy and its requirements. Training will be conducted to enable employees to comprehend the policy, identify violations, and report them through the appropriate channels.
  3. Refresher Training: Regular refresher training on the Whistle-blower Policy will be provided to ensure that employees clearly understand it and its requirements.
  4. Senior Management Training: Senior managers responsible for overseeing the policy implementation and handling whistle-blower reports will receive advanced training on handling whistle-blower allegations.
  5. Certifications: Employees will be required to certify that they have read, understand, and agree to comply with the policy.

This training approach will ensure that employees are informed about Willshir Whistle-blower Policy and equipped to fulfil their obligations if they observe or become aware of illegal or unethical activity.

Review and Revision

At Willshir, we understand the importance of keeping our Whistle-blower Policy updated and effective to ensure it aligns with legal and ethical considerations. This policy will be regularly reviewed to ensure that it remains current and effective.

As part of our review process, we will assess the effectiveness of the Whistle-blower Policy in achieving its objectives and determine whether any updates or changes are necessary. Our review process will include comprehensive assessments of existing practices, procedures, and controls that support this policy.

We will seek input from all relevant stakeholders in our organisation, including employees, managers, and executives, to ensure their contributions are considered in any policy revision. Additionally, we will consult with legal counsel to ensure that any updated policy remains in compliance with all relevant laws and regulations.

If updates or changes to the Whistle-blower Policy are necessary, we will communicate those changes to all employees and stakeholders to ensure awareness and understanding of the revisions. The revised policy will be available on our company’s internal website and other relevant channels.

Moreover, training and awareness programs will ensure all employees understand the revised policy and their obligations to report wrongdoing. All employees will also be encouraged to provide feedback and suggestions for improvement, ensuring that the Whistle-blower Policy effectively prevents and detects unethical or illegal behaviour.

We prioritise our Whistle-blower Policy’s continuous improvement and effectiveness. We are committed to conducting regular reviews, seeking relevant input, and updating as necessary. Through such proactive measures, we aim to create a culture of accountability, transparency, and ethical behaviour across our organisation.


We have established a confidential Whistle Blowing Hotline, which employees can use to report any concerns or incidents of misconduct. This hotline is managed by an independent third-party agency. Employees can report any matter, including suspected criminal or illegal conduct, without fear of retaliation. We have ensured that the identity of the individuals who make the report using the hotline will remain confidential.

In addition to the whistling hotline, employees are encouraged to report any incidents of misconduct to their line managers. We have provided training to all managers to receive whistleblowing disclosures carefully, addressing the concerns raised and respecting the confidentiality of the employees.

Finally, employees can also seek guidance from the RWillshir Legal department or Human Resources.

All employees are assured that they will be protected from retaliation for providing information about suspected or actual wrongdoings. We take all such reports seriously and will take appropriate action to address the concerns.

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