This policy describes how anyone — an employee, supplier, partner, counterparty or member of the public — can raise a concern about Kaelo Global in confidence, and how we handle what is raised.
1. Purpose
Kaelo Global runs as a deliberately small, privately held enterprise. The integrity of the operating model depends on the people who work in and around it being able to raise concerns without fear of reprisal. This policy sets out the channel for doing so and the standard to which we will respond.
2. What can be raised
Any concern about conduct that is — or that you reasonably believe to be — illegal, unethical, contrary to Kaelo Global’s policies, or harmful to the enterprise or to third parties. This includes (but is not limited to):
- Financial misconduct, fraud, or misuse of group assets.
- Bribery, corruption, or breach of sanctions.
- Modern slavery, forced labour, or any labour-rights breach in the operating businesses or supply chain.
- Harassment, discrimination, or breach of the working-culture standards described in our DEI policy.
- Health, safety, or environmental breaches.
- Data-protection breaches or improper handling of confidential information.
- Conflicts of interest involving Kaelo principals or staff.
3. How to raise a concern
Concerns can be raised through any of the following channels:
- Email: whistleblower@kaeloglobal.com — routed to an Operating Council member outside the operational chain of the matter raised.
- Post: a written letter marked “Confidential — Whistleblower” to the Kaelo Global head office, Dubai.
- Through a principal: any operating principal you trust within Kaelo Global is empowered to receive a concern in confidence and escalate it.
Concerns can be raised anonymously, although providing identification helps us investigate the matter more effectively and report back to you.
4. How we respond
- Receipt is acknowledged in writing within five working days.
- An initial assessment is conducted to determine the appropriate investigation path.
- Investigation is conducted by people independent of the matter raised. Where appropriate, external counsel is engaged.
- Findings are documented. Corrective actions are tracked to completion.
- The person who raised the concern receives written feedback on the outcome, to the extent we are lawfully able to share it.
5. Confidentiality and non-retaliation
We protect the identity of anyone raising a concern to the maximum extent possible consistent with conducting a fair investigation and meeting our legal obligations. Retaliation against anyone who raises a concern in good faith is prohibited and is itself a breach of this policy.
6. Bad-faith reports
This policy protects good-faith concerns even where the concern turns out to be unfounded. It does not protect reports knowingly made in bad faith. Such reports may themselves be investigated.
7. Oversight
The Audit & Compliance committee reviews aggregate whistleblower activity quarterly and reports to the Operating Council. Individual case detail is not publicised, in order to protect the people involved.
8. Contact
For any question about this policy: compliance@kaeloglobal.com.