1. INTRODUCTION
    1. BulkSMS ("the Company") is committed to fostering an environment of openness, transparency, and accountability. This Whistleblowing Policy is designed to encourage employees, contractors, and other stakeholders to report any concerns about wrongdoing within the organization without fear of reprisal.
  2. PURPOSE
    1. The purpose of this policy is to provide a mechanism for individuals to report any actions or behaviours that they believe violate laws, regulations, ethical standards, or the Company's policies and procedures.
  3. SCOPE
    1. This policy applies to all employees, contractors, suppliers, clients, and any other individuals associated with the Company ("Whistleblowers"). It encompasses all business activities, both domestically and internationally.
  4. REPORTING CHANNELS
    1. Whistleblowers are encouraged to report their concerns through established and confidential reporting channels, which may include direct communication with supervisors, management, the Human Resources department, or the designated whistleblower hotline or email.
  5. CONFIDENTIALITY AND ANONYMITY
    1. The Company is committed to protecting the confidentiality of Whistleblowers to the extent allowed by law. Whistleblowers have the option to remain anonymous when reporting concerns, and the Company will make every effort to maintain confidentiality during the investigation process.
  6. NON-RETALIATION
    1. The Company strictly prohibits any form of retaliation against Whistleblowers who report concerns in good faith. Whistleblowers are protected from adverse employment actions or any form of retaliation, and the Company is committed to taking appropriate measures to prevent and address retaliation.
  7. INVESTIGATION PROCESS
    1. Reports received under this policy will be promptly and thoroughly investigated. The Company will appoint a designated individual or team to conduct the investigation. Whistleblowers may be contacted for additional information during the investigation, and confidentiality will be maintained to the extent possible.
  8. REPORTING FALSE CLAIMS
    1. Making false or malicious allegations is a serious violation of this policy. Individuals found to be making intentionally false reports will be subject to disciplinary action.
  9. COMMUNICATION AND AWARENESS
    1. The Company will communicate the existence of this Whistleblowing Policy to all stakeholders and provide training to employees to ensure awareness and understanding of the policy and reporting procedures.
  10. COMPLIANCE WITH LAWS
    1. This policy is designed to comply with all applicable laws and regulations related to whistleblowing, including protection measures for Whistleblowers.
  11. REVIEW AND UPDATE
    1. This policy will be periodically reviewed to ensure its effectiveness and relevance. Amendments may be made to reflect changes in applicable laws or business practices.
  12. RESPONSIBILITIES FOR THE PROCESS
    1. The responsibilities for the preparation, verification, issue, filing and up-dating of this policy and associated processes is the duty of the Director: Operations or duly appointed representative. The monitoring, measuring and continual improvement of the procedure or process is the responsibility of the Compliance Officer or duly appointed representative.