1. Purpose of the Whistleblowing Policy
The purpose of this policy is to:
- Encourage employees, contractors, users, and third parties to report concerns about suspected unethical, illegal, or improper behavior within TELA.
- Ensure that any concerns raised are taken seriously, investigated promptly, and addressed appropriately.
- Safeguard individuals who report in good faith from retaliation, discrimination, or harassment.
- Ensure compliance with relevant legal and regulatory requirements, including those related to financial crime, data protection, and corporate governance.
2. Scope of the Policy
This policy applies to:
- Employees and contractors of TELA, including full-time, part-time, and temporary staff.
- Users of the TELA App who may encounter concerns regarding the company’s operations, practices, or conduct.
- Third parties, such as vendors, partners, or any individual or entity who may come into contact with TELA and its activities.
This policy covers concerns related to a range of potential wrongdoings, including but not limited to:
- Financial fraud, bribery, or corruption.
- Data breaches, unauthorized access to personal information, or any data privacy violations.
- Misuse of company resources or assets.
- Violation of laws, regulations, or industry standards.
- Discrimination, harassment, or unethical behavior.
- Conflict of interest or violation of ethical standards.
- Unsafe work practices or failure to maintain a safe working environment.
3. Reporting Channels
TELA provides multiple channels through which individuals can report concerns or allegations of wrongdoing:
- Internal Reporting Mechanism: Employees and contractors should report concerns through their line manager, HR department, or the designated Whistleblowing Officer.
- Whistleblowing Hotline: TELA provides a confidential whistleblowing hotline where employees, contractors, users, and third parties can report concerns anonymously, if preferred.
- Email: Reports can be submitted via the confidential email address.
- Online Reporting Portal: TELA operates an online whistleblowing platform, which allows individuals to submit detailed reports securely and anonymously if desired.
- Third-Party Reporting: In cases where employees, contractors, or users prefer to report concerns to an external party, TELA has partnered with an independent whistleblowing service provider to ensure confidentiality and impartiality.
All reports should provide as much detail as possible to enable proper investigation and resolution.
4. Handling and Investigation of Whistleblowing Reports
4.1 Confidentiality:
TELA will treat all reports with the utmost confidentiality. The identity of the whistleblower will be kept confidential to the extent possible, and reports will only be shared with those individuals or teams necessary for the investigation. In cases where the investigation requires revealing the whistleblower’s identity, the individual will be consulted and asked for consent.
4.2 Investigation Process:
Upon receipt of a whistleblowing report, the following steps will be followed:
- Acknowledgment: TELA will acknowledge receipt of the report within a reasonable time, usually within 3 business days.
- Initial Assessment: The Whistleblowing Officer or designated team will conduct an initial assessment to determine the seriousness of the concern and the appropriate course of action.
- Investigation: If the concern is deemed valid and serious, an internal investigation will be initiated. This may involve interviews, evidence gathering, and forensic analysis where necessary.
- Outcome: The results of the investigation will be communicated to the whistleblower, if their identity is known, and to relevant stakeholders within TELA. If the allegations are substantiated, appropriate disciplinary action or corrective measures will be taken.
4.3 Timeframe:
Investigations will be conducted as promptly as possible, but the timeframe may vary depending on the complexity and nature of the concern. Whistleblowers will be updated periodically on the progress of the investigation.
5. Protection for Whistleblowers
TELA is committed to protecting whistleblowers from retaliation. We will not tolerate any form of retaliation, harassment, or discrimination against individuals who report concerns in good faith. The following protections are in place:- No Retaliation: Whistleblowers who report concerns in good faith will not be subject to retaliation, including dismissal, demotion, suspension, or any form of discrimination.
- Confidentiality: TELA will take appropriate measures to ensure that the identity of the whistleblower is protected during the investigation process.
- Anonymity: Whistleblowers have the right to remain anonymous when reporting concerns. If the whistleblower chooses to disclose their identity, TELA will ensure that confidentiality is maintained to the extent possible.
- Support: Whistleblowers who fear retaliation will have access to support and can contact the Whistleblowing Officer or HR for assistance.
6. False Allegations and Malicious Reports
TELA encourages the reporting of concerns in good faith, and we understand that individuals may be genuinely concerned about wrongdoing. However, making false or malicious reports can undermine the trust and effectiveness of this policy. TELA will take appropriate action against any individual who knowingly makes false reports or engages in malicious whistleblowing. False reports are defined as those made with the intent to deceive, damage reputations, or cause unnecessary harm. Disciplinary action may include dismissal or legal action in cases where false reporting is proven.
7. Monitoring and Reporting
TELA will regularly monitor and review the effectiveness of this policy and the whistleblowing process. Reports of concerns and the outcomes of investigations will be reviewed regularly to ensure that they are handled appropriately and in line with TELA’s commitment to integrity and transparency.A quarterly report summarizing the whistleblowing activity (without revealing the identities of the whistleblowers) will be provided to senior management and the board of directors to assess the effectiveness of this policy.
8. Training and Awareness
TELA will provide regular training and awareness programs to all employees and contractors on the importance of whistleblowing, how to raise concerns, and the protections available to whistleblowers. The training will emphasize the need to uphold ethical standards and report potential violations of laws, policies, or regulations.
9. Policy Review and Updates
This Whistleblowing Policy will be reviewed annually and updated as necessary to ensure it remains in line with best practices, regulatory changes, and organizational requirements. All updates to the policy will be communicated to employees, contractors, and users.
10. Contact Information
For any questions regarding this policy or to report concerns, please contact the designated Whistleblowing Officer:Whistleblowing Officer
Email: report@tela.ng
Phone: +234 9133124223
Alternatively, you can use the whistleblowing hotline or online reporting portal.
Acknowledgment: By using the TELA App or engaging with TELA’s services, you acknowledge that you have read, understood, and agree to comply with this Whistleblowing Policy.
This Whistleblowing Policy is intended to maintain a safe and ethical work environment for all stakeholders, and we encourage everyone to report concerns promptly and responsibly.