Whistleblower Policy

1. Policy Statement:

At AHOY, we are committed to maintaining the highest standards of integrity, transparency, and ethical conduct across all aspects of our operations. We recognize that issues such as misconduct, dishonesty, or legal violations can occur despite our best efforts. To uphold our commitment, we encourage all employees, contractors, and stakeholders to report any concerns about unethical, illegal, or suspicious activities without fear of retaliation. This Whistleblower Policy provides a clear framework to protect individuals who report in good faith and ensures that reports are handled fairly, confidentially, and effectively, in compliance with UAE laws.  

2. Purpose and Objectives:

  • To provide a secure and feasible mechanism for reporting concerns regarding misconduct or violations of laws, regulations, or company policies. 

  • To protect whistleblowers from retaliation, discrimination, or unfair treatment. 

  • To promote a transparent culture rooted in accountability and integrity. 

  • To uphold compliance with UAE Federal Law No. 7 of 2016 on Combating Commercial Frauds and Money Laundering and other relevant legal frameworks. 

3. Scope and Applicability:

This policy applies to all employees, directors, contractors, vendors, business partners, and any other stakeholders associated with AHOY. It covers a broad spectrum of concerns, including but not limited to: 

  • Fraud, corruption, or bribery 

  • Financial irregularities or misreporting 

  • Violations of laws, regulations, or company policies 

  • Harassment, discrimination, or unethical conduct 

  • Data breaches or misuse of proprietary information 

  • Environment, health, and safety violations 

4. Reporting Channels  

To facilitate safe and accessible reporting, AHOY provides multiple channels: 

  • Dedicated Whistleblower Hotline: Confidential telephone line managed by an external provider. 

  • Email Reporting: Secure email address monitored by the designated compliance or HR team. 

  • Anonymous Reporting Portal: Secure online portal enabling anonymous submissions. 

  • In-Person Reporting: Direct communication with designated compliance officers or senior management, if preferred. 

All reports will be treated with the utmost confidentiality, respecting the whistleblower’s identity and privacy. 

5. Confidentiality and Anonymity 

AHOY commits to protecting the identity of whistleblowers to the greatest extent possible, subject to legal and investigative requirements. Whistleblowers are encouraged to disclose their identity to enable proper investigation; however, anonymous reports are also accepted and will be seriously considered and investigated. 

6. Protection Against Retaliation 

  • No Retaliation Policy: AHOY prohibits retaliation, discrimination, harassment, or any adverse action against anyone making a good-faith report. Retaliation offenders will face disciplinary measures, including termination of employment or contractual relationship, and legal action if applicable. 

  • Good-Faith Reporting: Whistleblowers are expected to provide honest and factual information. Malicious or unfounded reports made with malicious intent may be subject to disciplinary action. 

  • Protection Measures: Whistleblowers will be protected from dismissal, demotion, harassment, or any adverse treatment related to their reporting. 

7. Investigation Process 

  • All reports will be recorded, reviewed, and investigated promptly and thoroughly by a designated Compliance Officer or a special investigations team. 

  • Investigations will be conducted confidentially, maintaining fairness and due process. 

  • The whistleblower may be interviewed as part of the investigation process, and their input will be considered. 

  • Findings and recommendations will be documented, and appropriate corrective actions will be implemented. 

8. Handling of Reports 

  • Initial Acknowledgment: Whistleblowers will receive confirmation of receipt within a specified timeframe. 

  • Follow-Up: Regular updates regarding the investigation status will be provided, respecting confidentiality. 

  • Outcome: Upon conclusion, the whistleblower will be informed of any corrective measures taken, consistent with confidentiality and legal requirements. 

9. Record Keeping

  • Initial Acknowledgment: Whistleblowers will receive confirmation of receipt within a specified timeframe. 

  • Follow-Up: Regular updates regarding the investigation status will be provided, respecting confidentiality. 

  • Outcome: Upon conclusion, the whistleblower will be informed of any corrective measures taken, consistent with confidentiality and legal requirements. 

10. Training and Awareness  

  • All reports, investigation records, and follow-up actions will be securely stored, access limited to authorized personnel. 

  • Data will be retained in accordance with applicable laws and internal policies. 

11. Review and Continuous Improvement 

  • This policy will be reviewed annually to ensure effectiveness, relevance, and compliance with UAE legal requirements. 

  • Feedback from employees and stakeholders will be incorporated to improve the reporting and protection mechanisms. 

12. Legal and Regulatory Compliance

  • AHOY’s whistleblowing procedures are designed to align with relevant UAE laws, including Federal Law No. 7 of 2016 concerning anti-money laundering and anti-fraud measures, as well as other applicable regulations. 

  • Disclosures made in good faith and in compliance with