Whistleblower Policy

This policy describes how anyone, whether 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 is a deliberately small, privately held business. Whether it works honestly depends on the people in and around it being able to raise a concern without fear of the consequences. This policy sets out how to do that and the standard we hold ourselves to when we respond.

2. What can be raised

Any concern about conduct that is, or that you reasonably believe to be, illegal, unethical, contrary to our policies, or harmful to the business or to other people. That includes, and is not limited to:

• Financial misconduct, fraud or misuse of company assets.
• Bribery, corruption or a breach of sanctions.
• Forced labour, modern slavery or any breach of labour rights in our business or our supply chain.
• Harassment, discrimination or a breach of the working-culture standards described on our diversity, equity and inclusion page.
• Health, safety or environmental breaches.
• Data protection breaches or careless handling of confidential information.
• Conflicts of interest involving our principals or staff.

3. How to raise a concern

A concern can be raised through any of these routes:

• Email: info@kaeloglobal.com, marked confidential, which is passed to a principal outside the line of the matter raised.
• Post: a letter marked confidential and addressed to the whistleblowing contact at our Dubai office.
• Through a principal: any principal you trust can receive a concern in confidence and pass it on properly.

A concern can be raised anonymously. Giving your name helps us investigate properly and report back to you, and we understand why someone might prefer not to. If you can, include what happened, when, who was involved and anything that supports what you are describing, because a specific account is much easier to act on.

4. How we respond

• We acknowledge receipt in writing within five working days.
• We carry out an initial assessment to decide how the matter should be investigated.
• The investigation is carried out by people independent of the matter raised, and we engage outside advisers where that is appropriate.
• Findings are written down, and anything that needs correcting is tracked until it is done.
• The person who raised the concern receives written feedback on the outcome, as far as we are lawfully able to share it.

5. Confidentiality and no retaliation

We protect the identity of anyone who raises a concern as far as we possibly can, while still carrying out 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. That applies to obvious retaliation and to the quieter kind, such as work being withdrawn or a relationship cooling.

6. What we will not do

We will not ask you to prove a concern before we look into it, because most people raising something have part of the picture rather than all of it. We will not require you to raise it with the person the concern is about first. We will not treat a concern as closed simply because the person who raised it has left, and we will not use a settlement to stop someone speaking to a regulator.

7. Reports made in bad faith

This policy protects a concern raised in good faith, even where it turns out to be unfounded. It does not protect a report that someone knows to be false, and a report of that kind may itself be investigated.

8. Oversight

The principals review the pattern of concerns raised each quarter, including how long they took to resolve and what changed as a result. Individual cases are not publicised, in order to protect the people involved.

9. Contact

For any question about this policy, including how it would apply to something you are considering raising, write to info@kaeloglobal.com. You are welcome to ask a question without naming anyone.