Grievance & Whistleblower Procedure

Aim.  This grievance mechanism is a framework for addressing grievances and whistleblowing is a framework for reporting an alleged incident.  Both include incidents concerning Human Rights.

Terminology.  Grievances is also referred to as complaint.

Meanings.

1. A grievance or complaint is an allegation of improper or illegal conduct, which has occurred (or is about to occur), and is linked to the Company or its personnel.
2. Whistleblowing is a report of alleged improper and/or illegal conduct that has occurred or is intended to occur.

Roles.  This procedure plays two roles:

1. It can resolve complaints/incidents and provide effective remedies for harms.
2. It can help identify areas where performance should be improved.

Key Elements.  We believe that Hawki’s grievance procedure is: accessible, open, safe and fair.

1. Accessible.  This procedure features on the company website: https://www.hawki.co/security-risk-management/icoca
   1. The steps show how to submit a complaint or report and incident, the contact point, the timeframe for review of the complaint/report and the fact that complainant/whistleblower will be protected against retaliation.  Complaints/reports can be submitted through more than one channel: via the Contact Us page on the website, telephone, email or in person.
   2. Any complaint/report should be submitted in English.  Should you prefer to submit it in another language, the complaint/report must be translated into English as well, either by a person translator, or by an electronic translation (e.g. Google translate, or www.deepl.com).
2. Open.  This procedure is open to third parties, and not just to those who have a business relationship with Hawki, such as staff, clients and subcontractors.  People in the local community are able to complain/report to the Company.
3. Safe and Fair.
   1. This procedure is confidentiality.  Anonymous complaints/reports are accepted – it should be noted that anonymous reporting may make investigating a complaint/report more difficult.
   2. We are making Complainants/Whistleblowers aware that their identity can be limited to just the grievance officer, the person managing the complaint/report.

Personnel.  The designated officer is the HR Manager.  This person is responsible for managing complaints/reports and the overall functioning of the procedure.  The roles and responsibilities of everyone involved is as follows:

1. HR Manager.  The HR Manager is responsibilities include:
   1. Managing all grievances, complaints and reports.
   2. Updates of the policy.
   3. Communication of the policy.
   4. Accepting, reading, reviewing, investigations, interviews, appeals, and feedback of all grievances/reports.
   5. Implementation of all remedies.
   6. Training on this procedure.
2. Line Manager.
   1. Reporting to and supporting the HR Manager on this subject.
3. Directors.
   1. Legal compliance of the Company with regards to grievances, complaints and reports.
   2. Management of the HR Manager.
4. Complainants.
   1. To submit all grievances, complaints, reports using the correct process, in an eligible format, and using one of the correct communication methods.
   2. Support the Company in its review of the grievance/complaint.
   3. Both parties to the complaint/report shall commit to cooperate in good faith and respect any confidentiality need.
   4. Refresh your contractual obligations and in particularly the terms and conditions you signed up to.

Process.  The process for accepting and rejecting complaints/reports is as follows:

1. The ICOCA’s Code of Conduct (www.icoca.ch) applies to us.
2. If you are a client or a member of staff of this company, and are dissatisfied with any aspect of the service provided, including finances, you are entitled to complain.  Our policy is to look at complaints/reports objectively and take a constructive approach to reaching a satisfactory conclusion.  We recognise that complaints/reports may provide us with an opportunity to check the quality of our service and to make improvements to it in a particular case or generally.  Indeed, even if you do not have a complaint/report, your suggestions as to how our services might be improved will be welcome.
3. You can make a complaint/report to the member of staff who is responsible for the matter concerned or, if this is not appropriate or the complaint/report is in relation to more general matters, to our HR Manager.
4. A complaint/report will be acknowledged within three working days.  We will review your case carefully with the person handling the matter and make any wider enquiries within the company as may be necessary.  We will respond fully as soon as practicable and within 21 days.  If that is not possible, we will let you know when you will receive our full response.
5. Our response will usually be in writing, and we may suggest a meeting.  We will inform you of our views about your complaint/report and how we propose to resolve it.
6. If you are not satisfied with our response, you may refer your complaint/report to our COO, who will look at the matter afresh and will carry out any further investigations as may be necessary and in accordance with our Complaints and Whistleblower Policy, a copy of which will be provided on request.  They can be contacted at complaints@hawki.co.  If the complaint/report remains unresolved, you may refer it to ICOCA.
7. Before it will consider a complaint/report, ICOCA generally requires that a company’s internal complaints procedure has been exhausted with the client or member of staff.
8. You should bring your complaint/report to the ICOCA within six months of our final internal complaints procedure response and within six years of your grounds for dissatisfaction arising or three years from the deemed date of knowledge of these grounds.
9. ICOCA may:
   1. Investigate the quality of the professional service supplied by the company.
   2. Express a view on whether the company’s services are found reasonable; or
   3. Refer allegations that the company has breached rules of professional conduct.
10. ICOCA will not:
    1. Determine complicated issues of fact or law which can only be decided by a Court.
    2. Give legal advice; or
    3. Review the outcome of a court case.
11. ICOCA's website can be found at www.icoca.ch.  They can be contacted by email at secretariat@icoca.ch, by post at ICOCA, Geneva Nations 3rd Floor, Rue du Pré-de-la-Bichette 1, CH-1202 Geneva, Switzerland or by telephone on +41 22 727 07 53.
12. If you are not satisfied with the outcome of your complaint/report in relation to our services you may also apply to the court for an assessment but you will be responsible for the costs of such assessment if the case is dismissed.

Records. Hawki will keep records relating to complaints for at least seven years.