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Whistleblower Protection Policy

 

Purpose and Scope

Humanics Global Advisors LLC (“HGA”) is committed to the highest standards of ethical conduct, transparency, and accountability in all our operations. This Whistleblower Protection Policy (“Policy”) establishes a framework for the reporting and handling of suspected misconduct, and it applies broadly to all individuals and entities involved with HGA. This includes HGA employees, independent consultants, partner organizations, clients, and users of HGA’s digital platform. In line with best practices for nonprofits and companies, whistleblower protections under this Policy extend beyond employees to cover volunteers, contractors, and others associated with the organization[1].

The purpose of this Policy is to encourage early identification and reporting of any unethical, illegal, or suspicious activities related to HGA’s work, and to reassure whistleblowers that they can report concerns in good faith without fear of retaliation. Prompt internal reporting of concerns allows HGA to investigate and address issues before they escalate, thereby maintaining integrity and trust in our services

Policy Statement – Ethical Conduct and Commitment

HGA fosters a culture of honesty and open communication where misconduct is not tolerated. All HGA personnel and affiliates are expected to perform their duties in compliance with all applicable laws, regulations, and professional standards. We have zero tolerance for fraud, corruption, abuse of authority, conflicts of interest, data breaches, or any other wrongdoing in our operations. HGA fully embraces the principle that all activities must be conducted with the “highest standard of ethics”[2], as exemplified by the ethical guidelines of our multilateral clients (e.g. the World Bank’s consultant ethics rules).

Under this Policy, every individual covered has a responsibility to report any suspected misconduct. HGA encourages good-faith reporting by making multiple reporting channels available and by pledging strong protections for anyone who raises concerns. Retaliation against whistleblowers is strictly prohibited (see Section 5), and accountability for ethical conduct is enforced at all levels of the organization. This Policy aligns with HGA’s core values of integrity and transparency, and is integrated with our other compliance efforts, including donor-required ethics standards and internal confidentiality agreements.

Reportable Conduct (What to Report)

This Policy is intended for reporting any suspected unethical, illegal, or irregular conduct related to HGA. Whistleblowers are encouraged to report in good faith any activity or behavior that they reasonably believe to be misconduct. Examples of reportable issues include, but are not limited to:

  • Fraud or financial impropriety – e.g. theft, embezzlement of funds, false accounting, or misuse of project funds.
  • Corruption or bribery – offering or accepting bribes, kickbacks, or other improper inducements.
  • Abuse of power or authority – egregious misuse of one’s position, or exploitation of clients, consultants, or resources.
  • Conflict of interest – undisclosed personal or financial interests that conflict with HGA’s or a client’s interests.
  • Violation of laws or regulations – any breach of applicable law, donor rules, or contractual obligations (such as procurement fraud or anti-corruption violations).
  • Data breaches or privacy violations – unauthorized access, disclosure or misuse of confidential or personal data, or any cybersecurity incidents compromising HGA or client information.
  • Serious policy violations or unethical behavior – such as substantial breaches of HGA’s codes of conduct, confidentiality, or professional standards.
  • Unsafe, discriminatory, or abusive practices – including workplace harassment, discrimination, or other serious misconduct impacting individuals’ rights or safety.

HGA encourages reporting of any wrongdoing encountered, whether it involves HGA staff, consultants, clients, or any party related to an HGA project. It is important to note that whistleblower reports are not limited to financial matters; they may also cover health and safety risks, abuses of human rights, or other ethical concerns[3]. If an individual is in doubt about whether a situation qualifies, we encourage them to err on the side of reporting under this Policy. No matter the subject, all reports will be taken seriously and reviewed in accordance with Section 6 (Investigation Process).

Reporting Channels and Procedures

4.1 How to Report: HGA provides multiple channels for reporting a concern. Whistleblowers should use the method they are most comfortable with. Reports may be submitted through any of the following official channels:

  • Online Contact Form: Submit a report via HGA’s official contact form at https://humanicsgroup.com/contact-us. This form is accessible publicly through our website. It can be used to send a written description of the concern. You may choose to omit your name or identifying information if you wish to remain anonymous.
  • Dedicated Email: Send an email to info@humanicsgroup.org describing the issue or suspicious activity. This dedicated email inbox is monitored by HGA’s senior management (or a designated compliance officer). You may use a personal or alternate email account if you prefer not to use your HGA email. If you do not wish to reveal your identity, you may send from an address that does not identify you.
  • Internal Platform Support: For users of HGA’s DevTender digital platform, you may also report issues via the platform’s internal support ticket system. Logged-in consultants or client representatives can navigate to the “Support” section on the platform and create a support ticket detailing the concern[4]. The system will log the ticket and alert authorized HGA support staff[5]. (Please note: while the platform’s support mechanism is available for convenience, using the public contact form or dedicated email may be preferable for sensitive whistleblowing matters, especially if anonymity is desired.)

When making a report, provide as much detail as possible about the suspected misconduct (who, what, when, where, and how). Attach any evidence or supporting documents if available. However, do not attempt to conduct your own investigation or confront the individuals involved; simply report what you know or suspect.

4.2 Anonymous and Confidential Reporting: Reports can be made anonymously if the reporter chooses. HGA’s contact form and email channels allow for omitting personal identifying information. Anonymous reports will be investigated to the extent possible. Whistleblowers are encouraged (but not required) to provide contact information, as this enables HGA to seek additional information if needed and to provide follow-up feedback. If you do provide your identity, HGA will keep your identity strictly confidential as described in Section 7.

All reports, whether anonymous or not, will be handled in a confidential manner. HGA will ensure that information about the report is only shared with those who need to know in order to investigate or take action. This includes limiting knowledge of the report to the designated investigative team and relevant senior management, unless disclosure is required by law or necessary to effectively investigate (see Section 7 on confidentiality).

4.3 External Reporting: This Policy primarily focuses on internal reporting to HGA. HGA encourages internal reporting as the most effective way to address issues quickly. However, nothing in this Policy prevents any individual from reporting concerns directly to appropriate external authorities or regulatory bodies. Whistleblowers have the right to approach external regulators, law enforcement, or donor organizations (such as the World Bank’s integrity office or the UN’s oversight bodies) if they believe it is necessary. In many jurisdictions, whistleblowers are legally protected when reporting to government or oversight authorities. HGA will not retaliate against anyone for making a good-faith report to an external authority. (We do request that, whenever possible, concerns be raised internally first, so that HGA has an opportunity to address the problem directly.)

This multi-channel approach to reporting is intended to fulfill the requirements of international best practices, such as the EU Whistleblower Protection Directive’s mandate for effective confidential internal reporting channels[6]. We aim to make reporting as accessible as possible to all stakeholders.

Investigation Process

All reports under this Policy will be promptly and thoroughly investigated in a fair and objective manner. HGA will handle investigations internally or with external assistance as appropriate, depending on the nature of the allegations and the parties involved. The general process is as follows:

  1. Acknowledgment of Report: Within five (5) business days of receiving a whistleblower report, HGA will acknowledge receipt to the reporter (if the identity or contact information of the whistleblower is known). The acknowledgment may be a written email or message confirming that the concern has been received and will be taken seriously. (Anonymous reporters will not receive an acknowledgment, but their report will still be acted upon promptly.)
  2. Preliminary Assessment: Within ten (10) business days of receipt, HGA’s designated compliance officer or management team will conduct a preliminary review of the allegation. The purpose of this initial assessment is to determine the credibility and relevance of the report and to decide on next steps. This may involve reviewing any evidence provided, consulting internal policies, and identifying what kind of expertise or investigator is required. The whistleblower may be contacted (if possible) for any clarifications at this stage. After this assessment, HGA will decide whether the concern falls under this Policy and merits a full investigation. (If a report is found to be baseless or outside the scope of this Policy – for example, a routine HR grievance – the matter may be referred to the appropriate process instead. The whistleblower will be informed if their report will not be investigated under the whistleblower process, unless anonymous.)
  3. Full Investigation: If the preliminary assessment indicates the need for a formal investigation, HGA will aim to complete a comprehensive investigation within thirty (30) days. In more complex cases, or where external expertise or law enforcement involvement is needed, the investigation timeframe may extend up to sixty (60) days or more. The whistleblower will be updated if significant delays are anticipated. The investigation will involve gathering factual information, which may include reviewing documents/records, accessing relevant data (including audit logs from the DevTender platform, if applicable), and conducting interviews with witnesses or involved parties. The investigator(s) will remain objective and will give any individuals accused of wrongdoing a chance to respond to the allegations as part of a fair process.
  4. Investigation Team and Conflict of Interest: Investigations will be carried out by appropriate personnel with the requisite knowledge and authority. Depending on the subject matter, this could be HGA’s Managing Director, a designated Ethics/Compliance Officer, or an internal committee. In all cases, HGA will ensure that those investigating are not themselves implicated in the alleged wrongdoing and do not have any significant conflict of interest. For instance, if the report implicates a senior manager, that person will be excluded from the investigation process, and an alternate investigator (or an independent external investigator) will be appointed. HGA may engage external legal counsel, auditors, or other specialists to assist in an investigation where necessary to ensure impartiality and expertise.
  5. Escalation to External Authorities: If, at any point, the investigation uncovers potential violations of law or significant risks, HGA may escalate the issue to external authorities. This can include reporting to law enforcement agencies, regulatory bodies, or relevant client/donor organizations. For example, fraud or corruption in a donor-funded project may need to be reported to the donor or to governmental anti-fraud entities. HGA will comply with all legal reporting obligations. In situations where external reporting is not mandatory but is deemed appropriate (due to the severity of the misconduct), HGA’s management will make a case-by-case decision on involving outside authorities. Whistleblowers are not expected to report to authorities themselves—HGA will handle such escalation when warranted, though we will coordinate with the whistleblower if additional information is needed from them.
  6. Outcome and Feedback: After the investigation is concluded, the responsible investigators will compile their findings and determine the outcome. If the allegations are substantiated, HGA will take prompt corrective actions. These may include disciplinary action against wrongdoers (up to termination or contract cancellation), recovery of losses, reporting outcomes to clients or regulators, or implementing new controls to prevent future issues. If allegations are not substantiated, the case will be closed with no action against innocent parties. The whistleblower (if known) will be informed when the investigation is closed. We will strive to share as much information as is appropriate about the outcome, acknowledging the whistleblower’s concern. However, specific details might be limited by confidentiality obligations or legal constraints – for instance, privacy rights of those accused. Even if we cannot divulge full details, the whistleblower will at minimum be notified that the matter was investigated and resolved.

All investigations will be documented, and records will be kept securely. The timeframe targets (5 days for acknowledgment, 10 days for initial assessment, 30–60 days for completion) are guidelines; if more time is required at any stage, HGA will act diligently and keep relevant parties informed. Our goal is a thorough yet efficient process that respects the rights of all involved.

Confidentiality and Data Protection

Maintaining confidentiality is a cornerstone of this Policy. HGA will protect the confidentiality of whistleblowers, the information they provide, and the individuals or matters implicated, to the fullest extent possible consistent with the need to investigate.

  • Confidentiality of Whistleblower’s Identity: If a whistleblower discloses their identity when reporting, HGA will keep their identity confidential. The whistleblower’s name or identifying details will only be shared with those directly responsible for handling or investigating the report, and only on a need-to-know basis. HGA will not reveal the whistleblower’s identity to the person(s) accused or to other staff or external parties, unless required to do so by law. Even in that case, we will endeavor to inform the whistleblower beforehand and will only disclose what is legally necessary (for example, pursuant to a court order).
  • Confidentiality of Accused and Witnesses: Individuals who are the subject of a report, as well as witnesses involved, also have rights to confidentiality. Until a determination is made, allegations will be kept as confidential as practicable to protect the reputations of those involved. The investigation will be conducted discreetly. Any employees or consultants who become aware of an investigation must not disclose information to unauthorized persons. If an accusation is not substantiated, HGA will ensure that the individual’s standing is not unfairly affected by unfounded allegations.
  • Investigation Confidentiality: The details of an ongoing investigation (the specific allegations, evidence, and interim findings) will be kept confidential within the investigative team. Communication to the whistleblower during the process will be handled in a manner that does not compromise confidentiality (e.g., using secure channels). All related documentation will be stored securely.
  • Handling of Personal Data: Any personal data collected or reviewed during the whistleblower process (such as names, contact info, or other identifying information) will be handled in compliance with HGA’s data protection policies and applicable privacy laws (e.g., GDPR). Personal data is treated as highly confidential and safeguarded with appropriate technical and organizational measures[8]. In fact, under HGA’s consultant agreements, personal information is recognized as a special category of Confidential Information requiring a high degree of protection and indefinite confidentiality[9]. HGA will not disclose such data to third parties except as strictly necessary to investigate or as required by law[8]. Each party involved in the process is expected to similarly uphold confidentiality and data protection obligations.
  • Exceptions – Legal Requirements: If disclosure of certain information is required by law or official investigation (for instance, if a government authority or court subpoenas information), HGA may be obliged to comply. In such cases, we will only disclose the information that is legally mandated and will seek to maintain confidentiality of other details to the extent possible. We will also, if permitted, inform the whistleblower that such disclosure is being made.

All HGA staff and consultants are reminded that they have already agreed (via employment or consultant contracts) to confidentiality obligations that cover company and client information. This extends to any information involved in a whistleblowing case. Breaches of confidentiality by any party (e.g., revealing a whistleblower’s identity without authorization) will be taken very seriously and may result in disciplinary action.

Legal Framework and Compliance

This Whistleblower Protection Policy is designed to be compliant with and supportive of relevant whistleblower protection laws and regulations in the United States, the European Union, and other jurisdictions where HGA operates. While HGA is a private company, we strive to meet or exceed the standards set by these legal frameworks and global best practices:

  • U.S. Whistleblower Protection Laws: Various U.S. laws protect whistleblowers. The federal Whistleblower Protection Act (WPA) primarily protects federal employees, but corporate whistleblowers are protected under other statutes such as the Sarbanes-Oxley Act and the Dodd-Frank Act. These laws, among other things, prohibit employers from retaliating against employees who report fraud, safety violations, or other unlawful activities[7]. HGA, although not a public company, voluntarily upholds the spirit of these protections in our internal policies. We also comply with any specific whistleblower requirements that may apply under federal or state law (for instance, OSHA regulations for reporting safety issues, etc.).
  • EU Whistleblower Protection Directive (2019/1937): The EU’s Directive (EU) 2019/1937 sets a baseline for whistleblower rights across EU member states, including requirements for internal reporting channels, diligent follow-up, and protection from retaliation[6]. HGA supports these principles. Although HGA may not be legally obligated under the Directive (depending on jurisdiction and size thresholds), we have implemented core elements of the Directive’s approach: a confidential internal reporting system, timely feedback to the whistleblower, and strong anti-retaliation safeguards. We monitor developments in EU member state laws implementing the Directive to ensure our practices remain consistent with European standards.
  • Other International Standards and Best Practices: HGA’s approach to whistleblowing is informed by global best practices, such as guidance from the Organisation for Economic Co-operation and Development (OECD) and Transparency International on whistleblower policies. We recognize that effective whistleblower protections are crucial for combating corruption and fraud worldwide. In line with this, our Policy provides for multiple reporting avenues, confidentiality, and independent investigation, which reflect widely accepted best practice criteria.
  • Client and Donor Requirements: Many of HGA’s clients, including multilateral development banks and UN agencies, have their own strict anti-fraud and corruption policies. As a contractor or partner to such organizations, HGA is often required to maintain internal controls and report any suspected misconduct on projects. For example, World Bank–financed projects obligate contractors to observe high ethical standards and report wrongdoing. HGA integrates those expectations into this Policy. Should a whistleblower report involve a donor-funded project, HGA will handle it not only under this Policy but also in compliance with any notification or reporting duties we have to that donor. This ensures that our multilateral clients (e.g., the World Bank, United Nations) can trust that HGA will address issues promptly and transparently, as part of our contractual and ethical commitments[10].

In summary, this Policy is built to be robust and legally sound. It reflects the protections found in major whistleblower laws (confidential reporting channels, protection from retaliation, etc.) and it demonstrates HGA’s commitment to ethical compliance in the eyes of regulators, clients, and donors. We will review and update the Policy as needed to remain in alignment with any changes in law or best practice.

Alignment with Platform Workflows

HGA’s digital consulting platform (often referred to as the “DevTender” platform) and our operational workflows are designed to support the implementation of this Whistleblower Protection Policy. Key aspects include:

  • Integrated Issue Reporting: The DevTender platform includes a built-in Support and Issue Reporting module, which allows users (consultants and client organizations) to submit support tickets for any problems or concerns encountered[4]. This mechanism is integrated into the normal workflow for consultants and clients. If a platform user observes suspicious activity or unethical behavior during their interactions (for example, irregularities in a consultancy listing or payment process), they can report it through the Support section. Any such support ticket that indicates potential misconduct will be escalated internally under the whistleblower process. The platform logs these tickets and notifies HGA’s support staff for action[5], ensuring that no reported concern goes unnoticed.
  • Workflow Transparency: The technical specifications of the DevTender platform outline various user roles and processes (e.g., consultants applying to projects, financial transactions being processed, etc.). These processes have inherent checks and record-keeping that facilitate transparency and accountability. For instance, financial transactions are tracked and monitored within the system, and any discrepancies can be flagged by users or automatically by the system. HGA’s platform architecture thus complements whistleblowing: issues can surface either through user reports or system alerts, and both will trigger review. Our support workflows ensure that when an issue is raised, it is assigned, tracked, and resolved, consistent with the timelines and procedures in this Policy.
  • Audit Trails and Compliance Features: The platform’s design includes security and compliance features such as audit logs, role-based access controls, and regular compliance checks[11]. These technical measures mean that there is a clear record of actions (e.g., who accessed what data, when payments were approved, etc.), which can be crucial in investigating a misconduct allegation. HGA’s System Manager and administrators conduct periodic audits of system logs and data integrity as part of the platform’s maintenance. In the event of a whistleblower report, these logs and records can be utilized to investigate the matter thoroughly. The platform’s Continuous Monitoring and Incident Response protocols also align with this Policy by ensuring that any unusual activities or security incidents are promptly reported and addressed as potential compliance issues.
  • Consultant and Client Onboarding: As part of the onboarding process on the platform, consultants and partner organizations agree to HGA’s terms of service, code of conduct, and relevant policies. We explicitly communicate our expectation of ethical conduct and inform all users that they have a duty to report any observed misconduct. This Policy is made accessible through the platform (e.g., via the user dashboard or resource center), so that consultants and clients are aware of how to raise concerns. This integration of policy awareness into the user experience ensures that the whistleblowing mechanism is not an afterthought but a natural part of our platform’s governance.

In essence, HGA’s digital platform is built with features that reinforce the objectives of the Whistleblower Protection Policy. By aligning technology with policy, we provide multiple avenues for issue reporting (both through the platform and outside it) and ensure that any report can be acted upon efficiently within our operational workflows.

Policy Communication, Training, and Review

  • Communication and Accessibility: This Whistleblower Protection Policy is made available to all employees and consultants upon onboarding. It is included in HGA’s policy handbook and published on our internal portal. It is also accessible on our public website for transparency, so that clients, partners, and donors can review our commitment to whistleblower protection. Copies of the Policy may be provided directly to key stakeholders (such as donor agencies or contracting officers for multilateral clients) upon request, underscoring our compliance readiness and transparency.
  • Training and Awareness: HGA will incorporate whistleblower policy awareness into regular training sessions. Employees and consultants will receive training or informational materials on how to recognize misconduct and how to report it. This includes reminders of the channels available (Section 4) and assurances of protection (Section 5). Periodic refreshers or updates (for example, an annual ethics training) will include scenarios involving whistleblowing to reinforce understanding. Managers have a special duty to promote an open environment and to forward any concerns raised to them into the formal reporting process.
  • Review and Updates: HGA’s management will review this Policy at least annually, and additionally whenever significant changes occur in applicable law or our business environment. We will evaluate the Policy’s effectiveness, taking into account feedback, any incidents that occurred, and evolving best practices. If areas for improvement are identified (for example, the need for additional reporting channels or adjusted timelines), HGA will update the Policy accordingly. Any material changes to the Policy will be communicated to all personnel and, if appropriate, to clients and partners. The updated Policy will be redistributed and replaced in official repositories.
  • Compliance Audits: From time to time, HGA may conduct audits or hire external experts to assess our internal controls, including our whistleblower program, as part of our commitment to strong governance. We will ensure that our processes under this Policy are documented and can demonstrate compliance with legal requirements and donor expectations. This preparedness is especially important for maintaining the confidence of multilateral clients like the World Bank or UN, who may audit contractors’ compliance programs.
  • Leadership Oversight: The ultimate responsibility for the implementation of this Policy rests with HGA’s leadership. The Managing Director or a designated senior officer (such as a Compliance Officer) will oversee the whistleblower system, ensure investigations are conducted properly, and report to HGA’s board (if applicable) or principals on any significant matters arising. Leadership will also ensure that no whistleblower is subject to retaliation and that any need for resources or improvements to the program is addressed.

This Policy is effective as of the date of issuance and will remain in effect until superseded by a revised version. All HGA personnel, consultants, and affiliates are expected to adhere to both the letter and the spirit of this Policy. By working together to uphold these principles, we reinforce an organizational culture where ethics and accountability are paramount, and where anyone can speak up about concerns knowing they will be heard and protected.

[1] [3] [7] Whistleblower Protections for Nonprofits | National Council of Nonprofits

https://www.councilofnonprofits.org/running-nonprofit/ethics-accountability/whistleblower-protections-nonprofits

[2] [8] [9] [10] HGA_Consultant_Contract_Template.docx

file://file-GA7v2hdnXhXEYmWj3q3gXG

[4] [5] [11] HGA_Digital_Platform_Technical_Specifications.pdf

file://file-LERZnDM52Sh8kLN2RatZB5

[6] Protection for whistleblowers – European Commission

https://commission.europa.eu/aid-development-cooperation-fundamental-rights/your-fundamental-rights-eu/protection-whistleblowers_en