Whistleblowing is the process during which you are encouraged to report wrongdoing within Minor through a formal and confidential channel.

Whistleblowing is important for fostering high ethical standards and thus maintaining customer and public confidence in an organisation and its operations. By blowing the whistle you can contribute to preventing the possible escalation of misconduct!

We want to hear from you if you suspect or witness any wrongdoing in the following matters:

• fraud and embezzlement;
• bribery and corruption;
• breach of law and regulations (national or international);
• violation of the Company’s Code of Conduct and any other policy or procedure;
• gross negligence, gross waste, or mismanagement;
• bullying or harassment;
• conflict of interest;
• unauthorized use of Company's funds or resources
• accounting – a violation of any internal accounting controls and auditing matters, including complaints regarding attempted or actual circumvention of internal accounting controls or Company’s accounting policies;
• abuse of authority; and
• retaliation against employees who make reports.

Also, Wrongdoing can include any action resulting in damage or risk of harm to financial performance, human rights, the environment, public health and safety, safe work practices, or the Minor's reputation. The wrongdoing or the harm can have happened in the past or is currently happening or could happen in the future.

Team Members - anyone who works on the Company’s behalf, including permanent or contract employees, trainees, interns, consultants, contractors, executive officers and board members, current and former; and Business Partners - contractors, consultants, service providers, suppliers, joint venture partners, and any other business partners who accepted the Business Partner Code of Conduct.

It is the responsibility of all Stakeholders to report concerns about violations of the Team Members Code of Conduct and Business Partner Code of Conduct (together, the “Code of Conduct”) or suspected violations of law or regulations that govern Company’s operations.

To enable a thorough investigation, you should include a detailed description including what has happened, as well as when and where it happened. You do not have to have proof of your suspicions, but a report should always be submitted in good faith. You may upload text files and pictures to your report.

Please see the form below.

Whistleblowing is the process during which you are encouraged to report wrongdoing within Minor through a formal and confidential channel.

Yes, we take all reasonable steps to protect the identity of whistleblower, which will be known only to the report recipient or case manager, unless the issue requires investigation by law enforcement or a consent provided by the whistleblower.

If a whistleblowing report was made in good faith, but the wrongdoing was not confirmed by the investigation, no action will be taken against the whistleblower. As much as we encourage honest reporting, we do not tolerate false reports. If a report was made with malicious intent or for personal gain, we reserve the right to take action against that particular individual.

We want to be transparent and outline the investigation process of a report submitted through our whistleblowing channels. Below, you will find brief explanation of the investigation process:

• Receipt of the Report. When a report (anonymous or otherwise) is received, it will be forwarded to the Whistleblower Committee.
• Evaluation. If the report has enough information, the Whistleblower Committee will perform an initial assessment to confirm that the report is a valid report, evaluate the case and adopt an investigation plan. For a report to be fully investigated, it must contain sufficient information to form a reasonable basis for investigation. A whistleblower reporting anonymously should provide as much information as possible not to compromise the ability to investigate the report fully. At this stage, the Whistleblower Committee may reach out to you for additional information through available channels.
• Investigation. The Whistleblower Committee will assign the investigation to the internal or external party, depending on the risk, urgency, and case complexity. Once the investigation is concluded, a report outlining the findings and recommendations will be adopted by Whistleblower Committee. The Whistleblower Committee may also bring such a complaint to the attention of Executive Management, or hire outside advisors such as lawyers, accountants, and auditors to conduct the investigation.
• Action. The Whistleblower Committee will determine appropriate actions against the wrongdoer(s) and send the update to you. You will be informed of the outcome of the investigation, subject to data privacy and confidentiality obligations.

As part of our investigative process, we will send updates to you. These updates can include confirmation of the receipt of a report, request for additional information, confirmation that the Company has begun the investigation, and the outcome of the investigation and action that were taken. Our commitment is that you will be updated while the investigation is ongoing. We will strive to provide as much feedback on the investigation as possible.