Document
Whistleblower Policy
Onesta Food and Beverage Limited (Onesta) provides channels through which employees, contractors, suppliers, customers, and other stakeholders can raise concerns about suspected wrongdoing, in confidence and without fear of retaliation.
1. Purpose
The purpose of this policy is to support a culture of openness and accountability by enabling concerns about wrongdoing to be raised and investigated promptly and fairly.
2. Scope
This policy applies to all individuals who interact with Onesta, including directors, officers, employees, agency workers, contractors, suppliers, customers, and members of the public.
3. Reportable concerns
Concerns that may be raised under this policy include:
- Breach of law or regulation.
- Breach of the Code of Conduct, the Anti-Bribery Policy, or other Onesta policies.
- Fraud, theft, or financial misconduct.
- Bribery, corruption, or facilitation payments.
- Food-safety, product-safety, or environmental risks.
- Health and safety risks to people.
- Discrimination, harassment, or abuse.
- Modern slavery, forced labour, or child labour in operations or supply chain.
- Data-protection breaches.
- Deliberate concealment of any of the above.
4. Channels
Concerns may be raised:
- To the individual's line manager, where appropriate.
- To the Head of Human Resources or the Head of Legal.
- By email to ethics@onestabd.com.
- By letter marked "Confidential" addressed to the Chair of the Audit Committee, care of the head office in Dhaka.
Anonymous reports are accepted but may limit the ability to investigate. The reporter is encouraged to identify themselves so that follow-up can take place.
5. Confidentiality
The identity of the reporter is kept confidential to the extent reasonably possible, consistent with the need to conduct a fair investigation and to comply with law.
6. Non-retaliation
Onesta does not tolerate retaliation, victimisation, or detrimental treatment of any person who raises a concern in good faith under this policy, regardless of whether the concern is substantiated. Acts of retaliation are themselves a serious breach of policy and may result in disciplinary action up to and including termination.
7. Investigation
Concerns are reviewed promptly. An initial assessment determines the appropriate scope and method of investigation. Investigations are conducted under the direction of the Legal function or, where appropriate, by an independent person. Findings, decisions, and any actions are documented.
8. Feedback
Where the reporter is identified, the reporter is informed of receipt of the concern and, to the extent permitted by law and confidentiality, of the outcome of the investigation.
9. False reports
Deliberately false or malicious reports are themselves a breach of policy and may result in disciplinary action.
10. External reporting
Nothing in this policy prevents a person from making a protected disclosure to a competent authority in accordance with applicable law.
11. Records
Records of reports and investigations are maintained in accordance with applicable law and Onesta's records-retention schedule.
12. Responsibility
The board endorses this policy. The Audit Committee oversees its operation. The Head of Legal maintains the policy.