Whistleblowing Policy

Purpose and scope
1. Beyond ONE (the Company or "we") is committed to conducting its business legally and with honesty and integrity at all times. However, all organisations face the risk of their activities going wrong from time to time. We believe we have a duty to take appropriate measures to identify such situations and attempt to remedy them. By encouraging a culture of openness and accountability within the Company, we believe that we can help prevent such situations occurring.
2. This same standard applies to our people, our consultants and contractors, and all people in companies we invest in ("you"). We expect you to maintain high standards in accordance with our code of conduct and to report any wrongdoing that falls short of these fundamental principles. It is your and our responsibility to raise any concerns about such wrongdoing within the workplace.
3. The aim of this policy is to encourage you to raise any matters of genuine concern without fear of reprisal, knowing you will be taken seriously and that the matters raised will be investigated appropriately and treated confidentially.
4. "Whistleblowing" is the reporting of suspected wrongdoing involving the Company such as actions or omissions considered illegal, contrary to Company policy or established procedure or outside the scope of an individual's authority. Examples include:
  1. criminal offences
  2. bribery, corruption, fraud or tax evasion
  3. danger to the health and safety of any individual, including unsafe working conditions
  4. disregard or violation of regulatory obligations
  5. miscarriages of justice
  6. false or inaccurate allegations
  7. a bullying culture (across a team or organisation; individual cases of bullying are addressed as an HR matter)
  8. deliberately hiding of any of the above.
5. This policy does not form part of any contract of employment; we may amend it at any time. We will make the latest version of this policy available at www.beyond.one.
When to use this policy
1. There is a difference between whistleblowing and raising an HR grievance:
  1. whistleblowing involves misconduct – typically, activities that are illegal, dangerous and/or dishonest.
  2. a grievance is a complaint relating to an individual’s own employment position or personal circumstances at work.
2. This policy does not address HR grievances. If you have a complaint about your personal circumstances, then contact your manager and/or the HR Department
Our guarantee
1. We are committed to the principles set out in this policy. If you raise a concern in good faith about suspected wrongdoing in our business, we will do everything we lawfully can to ensure you will not suffer any form of retribution or negative treatment and that your concern will be treated confidentially, seriously and in accordance with this policy.
2. If you wish to remain anonymous, we will respect this request and, unless the law requires otherwise, we will make every effort to keep your identity secret.
3. We will handle investigations promptly and fairly, but if you have made a disclosure and you are not satisfied with the investigation or its conclusion, please write directly to the Group Chief Executive Officer or the MTIH board detailing your concerns.
Options for raising a concern
1. You may report suspected wrongdoing in any of the following ways:
  1. Contact your immediate manager
  2. Send an email to [email protected]
  3. Contact the Company’s Chief People Director:
    [email protected]
    +971 4 369 7505
  4. Contact the Company’s Chief Legal Officer:
    [email protected]
    +971 4 369 7505
  5. Raise the concern with the following outside law firm (the "Law Firm"), who has been mandated to advise you about the matter at the Company’s cost:
    Michael Hancock
    KLME Law
    [email protected]
    +971 4 409 6794/ +971 50 315 7477
  6. If you do not want to report the matter to any of the above-mentioned individuals, you may send an email or anonymous email to the Law Firm. To send an anonymous email, you may use one of the sites referred to in the following article: https://www.hongkiat.com/blog/anonymous-email-providers/
  7. You may also report the matter directly to the police. For criminal wrongdoing, this may be a legal obligation, and you may discuss this confidentially with the Law Firm at our cost.
  8. For an investigation to be useful, as much of the following information as possible should be provided:
    - When did the wrongdoing take place? (dates)
    - Who was involved? (names)
    - What happened? (explanation and elaboration)
    - Provide any email correspondence or other documents that would help in the investigation
2. Any investigation is confidential, respecting applicable data protection laws as well as all other applicable local reporting obligations.
Responding to concerns raised
1. The Company will appoint a case manager responsible for leading the investigation.
2. The case manager will address all legitimate concerns appropriately, consistently, fairly and professionally based on available, actionable, and provided information.
3. The case manager will assess the information and supporting evidence received and, unless the matter was sent anonymously, invite you to a meeting or a conference call to discuss the matter.
4. After the meeting or the conference call, the case manager will usually make internal enquiries which may be formal or informal depending on the nature of the concern raised, to determine whether a more detailed investigation is appropriate. The case manager will report back to you and, if appropriate or required, to the police.
5. All Company officers, directors and staff must cooperate with the investigation.
6. If you have given your name, we will keep you informed of the case manager’s name, the progress of the investigation and when it is completed. The length and scope of the investigation will depend on the subject matter of the disclosure. We will, however, aim to deal with all disclosures in a timely manner.
7. The Company and the case manager may not be able to inform you of any matters which would risk infringing any laws, including data protection laws and duties of confidentiality owed to others.
Confidentiality
1. We will do everything we lawfully can to ensure your concern will be treated confidentially and anonymously if that is your wish. To help in the investigation, you should only discuss the matter with those leading the investigation, except you should disclose the matter to the police if you have a legal obligation to do so (see paragraph 4.a.vii).
2. Depending on the facts of the matter, you may be requested to be a witness regarding the wrongdoing, where disciplinary or other proceedings follow the investigation. If you agree to be a witness, you will be offered the protections set out in the policy in section 7. If you are currently an employee of the Company, the Law Firm will advise you at the cost of the Company.
3. Although a concern may be made anonymously, we encourage you to disclose your name and to act as a witness. If this is not done, it will be harder to investigate properly or give you feedback on the outcome of any investigation.
4. The case manager will consider matters reported anonymously at his or her discretion, by considering factors such as the seriousness of the issue raised, the credibility of the concern and the likelihood of confirming the allegation from other sources.
Protection and support for those raising concerns
1. We are committed to good practice and high ethical standards and are supportive of those who raise a matter in good faith under this policy, even if they turn out to be mistaken.
2. No individual whatever their seniority in the Company should threaten or retaliate against an individual who has raised a matter under this policy and the Company will not tolerate any such harassment or victimization. If you have suffered such treatment, please report this to a person identified in section 4.a immediately. Anyone involved in such conduct may be subject to disciplinary action including termination with cause. In the case of contractors and consultants, the Company may request the exclusion of the concerned individuals from further dealings with the Company and request the contracting entity to conduct a formal enquiry and report on its findings.
3. However, to protect all concerned, those who raise a concern frivolously, maliciously and/or for personal gain and/or who make an allegation they do not reasonably believe to be true and/or in the public interest may be subject to disciplinary action.
Further information and contacts
1. If you have any queries about the application of this policy, please contact any of people mentioned in paragraph 4.a.

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