ORG-200 Whistleblower Policy
Prepared by: Internal Auditor / HR
Approved by: Chris Purdy
Effective: August 13, 2020
Updated: August 13, 2020
A whistleblower is a DKT employee who reports an activity that he/she considers to be illegal, dishonest, severely inappropriate, or against DKT internal policies and procedures.
Examples of such activities / attitudes include non-compliance with policies or procedures, adulterated financial or statistical reporting or application of internal controls, unethical business conduct, concerns about employee health risks, sexual harassment, or discrimination based on race, country of origin, gender, sexual preference, religion, or physical challenge.
Policy and Reporting Process
The whistleblower is not responsible for investigating the activity or for determining fault or corrective measures.
If an employee has knowledge of or a concern of such activity, the employee should contact his/her immediate supervisor. If such action is not possible or the supervisor’s response is not adequate, the employee may contact DKT headquarters through the confidential hotline email. This email goes to DKT’s internal auditor and DKT human resources department. If so desired, you may include a copy to the DKT President (email: email@example.com).
The email is: firstname.lastname@example.org
While the employee is not expected to prove the allegation, the employee should be prepared to be interviewed and to submit any evidence available. Every effort will be made to protect the confidentiality of the complainant, and harassment or retaliation of any sort against any complainant will not be tolerated. While anonymous complaints will be accepted, employees are encouraged to identify themselves in order to increase the credibility of the complaint and to facilitate follow-up investigation. If so desired or required by the whistleblower, DKT will maintain the confidentiality of the whistleblower. Allegations, however, will be shared with the accused individuals to ensure their legal rights of defense, should such be required.
Malicious or knowingly false allegations, particularly with the evident purpose to harm the individual denounced may result in disciplinary action. DKT will not retaliate against a whistleblower for having ‘blown the whistle’ and will protect said whistleblower from retaliation by their manager or the senior officer in the country, unless the whistleblower is found to have knowingly made false allegations. Employees should not fear retaliation such as termination, compensation decreases, or poor work assignments and threats of physical harm for having engaged in whistleblowing.
Action taken will be dependent on the nature of the concern. A determination will be made as to how and if an investigation will be conducted, while maintaining the confidentiality of the complainant. Some concerns may be resolved without the need for further investigation. If an investigation is deemed appropriate, it will be conducted promptly with DKT resources. A written report, including recommendations, will be submitted to the President & CEO, and, if appropriate, to the senior management and/or the Board of Directors. As appropriate, corrective action will be taken including but not limited to a warning, letter or reprimand, suspension with or without pay, and/or termination of employment. Any questions regarding this policy may be submitted to the President & CEO.