- Introduction
Davis & Shirtliff Group is committed to the highest standards of openness, integrity, and accountability. This Whistleblowing Policy is designed to encourage all stakeholders - including staff, customers, suppliers, and regulators - to report any malpractice, lapses in integrity, or illegal acts. Our goal is to ensure that all reported cases of suspected wrongdoing are reviewed and investigated in a timely manner and necessary action taken. - Policy Statement
The Group is dedicated to conducting its business lawfully, ethically, and with integrity and has zero tolerance to unethical behavior or inappropriate practices. - Policy Objectives
The objectives of this policy are to:- Encourage reporting of improper, unethical, or inappropriate behavior at all organizational levels for action.
- Ensure all stakeholders feel supported in speaking up in confidence and reporting suspected improper, unethical, or inappropriate matters.
- Provide clear procedures for reporting identified matters of concern.
- Manage all disclosures in a timely, consistent, and professional manner.
- Assure stakeholders that all reports are taken seriously, treated confidentially, and managed without fear of retaliation.
- Scope of the Policy
This policy covers, but is not limited to the following:- Fraud, misappropriation, or misuse of company resources.
- Corruption, bribery, or blackmail.
- Criminal offenses.
- Failure to comply with legal or regulatory obligations.
- Any form of discrimination, harassment, or unfair people practices.
- Endangering the health and safety of individuals.
- Environmental damage.
- Lapses in Group internal controls.
- Misuse or destruction of company information and records.
- Stakeholders have a legal and moral duty to report such matters to enable management take appropriate measures to address them.
- Reporting Procedures
Stakeholders can report concerns through the following confidential channels:- External Anonymous Reporting Channels:
Below reporting channels are independently operated by Deloitte South Africa:- Email – This email address is being protected from spambots. You need JavaScript enabled to view it.
- Website – www.tip-offs.com
- Calls through toll free Ethics Hotlines:
- Kenya - 0800 722 626
- Tanzania - 0800 780 026
- Uganda - 0800 100 255
- Zambia +260 971 231 250
- Rwanda, DR Congo, South Sudan, Zimbabwe, Ethiopia, Somalia and Burundi - +27 31 571 5307
- International postal address for letters and support documentation:
- Deloitte Tip-offs Anonymous, PO Box 774, Umhlanga Rocks, 4320, South Africa
- Internal Reporting Channels
- Email: This email address is being protected from spambots. You need JavaScript enabled to view it.. Emails are received by Mike Eldon, an independent non-executive director who will subsequently direct an investigation into the matter reported.
- By contacting your Line Executive or the Internal Audit Department.
- External Anonymous Reporting Channels:
- Investigation Process
Upon receiving a report, the following steps are taken:- Report acknowledgment: The whistleblower will be informed of who is handling the matter, how to contact them, and any further assistance required (if the whistleblower has disclosed their identity).
- Investigation: A thorough investigation will be conducted. The investigator will provide as much feedback as possible without infringing on the confidentiality owed to others.
- Outcome: The findings will be reviewed, and recommendations made to management for appropriate actions to be taken.
- Feedback: Where appropriate, the whistleblower will be informed of the outcome of the investigation.
- Confidentiality
All reports will be handled in strict confidence, and the identity of the whistleblower will be protected unless disclosure is required by law or necessary for the investigation. - Whistleblower Protection
The Group strictly prohibits any form of retaliation against individuals who report concerns in good faith. Any retaliatory actions will be treated as serious violations of company policy and subject to disciplinary measures. - False Reporting
Deliberate false or malicious reporting is a serious offense. Any individual found to have knowingly made a false report will be subject to disciplinary action. - Approval and Adoption
This policy has been approved and issued by the Group’s Executive Management. The policy is endorsed and supported at the highest level and serves as a statement that improper, unethical, or inappropriate behavior within the organization is unacceptable.
Whistleblowing Policy
Whistleblowing Policy
- Details
Dundori Road, Industrial Area
Nairobi
P.O Box P.O Box 41762 - 00100
Kenya
