Whistleblowing Policy

Introduction

At galaxefi, we are committed to maintaining the highest standards of integrity, transparency, and accountability in all aspects of our operations. To uphold these values, we encourage employees, stakeholders, and partners to report any concerns about unethical or illegal activities without fear of retaliation. This Whistleblowing Policy outlines the procedures for reporting and handling such concerns.

Purpose

The purpose of this policy is to:

  • Provide a clear and confidential process for reporting suspected misconduct, fraud, or violations of company policies.
  • Protect whistleblowers from retaliation or discrimination.
  • Ensure that all reports are investigated thoroughly and fairly.
  • Promote a culture of transparency and accountability within the organization.

Scope

This policy applies to all employees, contractors, suppliers, partners, and other stakeholders associated with galaxefi. It covers a wide range of concerns, including but not limited to:

  • Fraud or financial misconduct
  • Legal or regulatory violations
  • Health and safety risks
  • Environmental damage
  • Discrimination or harassment
  • Any other unethical or illegal activities

Whistle-Blowers

The following individuals can typically blow the whistle:

  • Employees: This includes full-time, part-time, and temporary staff members.
  • Contractors: Individuals or organizations contracted to provide services or work for the company.
  • Suppliers and Vendors: Businesses or individuals providing goods or services to the company.
  • Partners: Business partners or joint venture participants who have an interest in the operations of the company.
  • Customers: In some cases, customers who witness unethical behavior or violations related to the company’s operations may also blow the whistle.
  • Other Stakeholders: This can include shareholders, community members, or any other individuals who have a legitimate interest in the ethical conduct of the company.

The above individuals are typically protected under the whistleblowing policy and encouraged to report any concerns about unethical, illegal, or unsafe practices within the organization.

Reporting Procedure

Reporting Channels

Employees and stakeholders can report concerns through the following channels:

  • Email: legal@galaxefi.com
  • Hotline: +92-3000-3G1-T11
  • In-Person: Concerns can also be reported directly to a designated officer or through the Human Resources department.

Anonymity and Confidentiality

Reports can be made anonymously if the whistleblower prefers. All reports will be treated with the utmost confidentiality, and the identity of the whistleblower will be protected to the fullest extent possible.

Investigation Process

Upon receiving a report, the following steps will be taken:

  • Acknowledgment: The report will be acknowledged within 24 hours.
  • Preliminary Assessment: A preliminary assessment will be conducted to determine the validity of the report and whether further investigation is necessary.
  • Investigation: A thorough and impartial investigation will be carried out by the designated team or external experts, depending on the nature of the concern.
  • Outcome: The whistleblower will be informed of the outcome of the investigation, subject to legal and confidentiality considerations.

Protection Against Retaliation

Retaliation against anyone who reports a concern in good faith is strictly prohibited. Any employee or stakeholder found to have retaliated against a whistleblower will be subject to disciplinary action, up to and including termination of employment or contract.

False Reports

While the company encourages reporting of genuine concerns, it also recognizes the need to protect individuals from false or malicious allegations. Any person found to have intentionally made a false report will be subject to disciplinary action.

Responsibilities

Typically, the responsibility for handling whistleblowing reports falls to the Legal Department.

  • Whistleblowers: Are responsible for reporting concerns in good faith and providing as much detail as possible to facilitate an effective investigation.
  • Managers and Supervisors: Are responsible for fostering a culture of openness and integrity, ensuring that employees feel safe to report concerns without fear of retaliation.
  • Designated Officer and/or Whistleblower Committee: Is responsible for overseeing the whistleblowing process, ensuring that all reports are handled confidentially, promptly, and fairly.

The process often involves:

  • Legal Department: Ensures that all reports are handled in compliance with laws and regulations. They also investigate the validity of the claims.
  • Whistleblowing Officer: This individual or committee is specifically tasked with receiving and managing whistleblower reports confidentially and impartially.
  • CEO or Director: May get involved when the whistleblower report involves serious allegations or requires executive decision-making.

Review and Updates

This Whistleblowing Policy will be reviewed periodically to ensure its effectiveness and alignment with legal and regulatory requirements. Any updates or changes will be communicated to all employees and stakeholders.

Contact

galaxefi is committed to maintaining an ethical work environment where concerns can be raised and addressed without fear. By adhering to this policy, we aim to uphold the trust and integrity that are essential to our continued success and reputation. For more information please feel free to reach out to us: