Whistle-blowing Policy
 

1. Introduction

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We are committed to the highest standards of integrity, ethics, and accountability in all aspects of our business operations. We encourage a culture of openness where employees, suppliers, and stakeholders feel safe and supported in raising concerns about any illegal, unethical, or improper conduct within the firm. This Whistle-blowing Policy outlines our approach to handling such concerns in a confidential and responsible manner.

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2. Purpose of the Policy

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The purpose of this policy is to:

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• Encourage individuals to report genuine concerns about misconduct or malpractice without fear of retaliation or victimisation.

• Provide a clear framework for reporting concerns and ensure that they are addressed in a timely, confidential, and appropriate manner.

• Protect Whistle-blowers from any form of discrimination, harassment, or disadvantage as a result of raising a concern.

• Promote a culture of accountability, transparency, and ethical behaviour within Arafino.

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3. Scope of the Policy

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This policy applies to all employees, contractors, suppliers, clients, and other stakeholders who have a relationship with Arafino. It covers concerns related to, but not limited to:

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• Fraud, corruption, or financial malpractice

• Bribery or unethical business practices

• Breach of legal or regulatory obligations

• Endangerment of health and safety

• Environmental harm

• Modern slavery or human trafficking

• Misuse of company assets or resources

• Improper conduct or unethical behavior

 

This policy is not intended for raising personal grievances (e.g., regarding employment terms, pay, or harassment), which should be addressed through the company’s grievance procedures.

 

 

4. Raising a Concern

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We encourage anyone who suspects misconduct to report their concerns at the earliest opportunity. Concerns can be raised in the following ways:

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• Internal Reporting:
  If you are an employee, you should initially raise concerns with your line manager or a senior member of the management team. If this is not appropriate or you feel uncomfortable, you may bypass normal channels and report directly to the designated Whistle-blowing officer.

• Whistle-blowing Officer:
  Simon Bonney (simon.bonney@arafino.com)

• External Reporting:
  If internal reporting is not suitable, or if the Whistle-blower believes that the matter is not being adequately addressed, they may raise the concern with external bodies, such as regulators or law enforcement agencies.

 

We encourage that concerns be reported in writing, detailing the nature of the concern, relevant facts, and any supporting documentation. This ensures a thorough and effective investigation.

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5. Confidentiality and Anonymity

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We recognise the importance of confidentiality when handling Whistle-blowing reports. To protect the Whistle-blower:

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• Confidentiality: All concerns raised will be treated with the strictest confidence, and the identity of the Whistle-blower will not be disclosed without their consent unless required by law.

• Anonymity: Whistle-blowers may choose to report concerns anonymously. However, anonymous reporting may limit the scope of our investigation, as we may not be able to ask follow-up questions or provide updates.

 

 

6. Protection for Whistle-blowers

 

Arafino Advisory Limited is committed to ensuring that no Whistle-blower suffers any form of retaliation as a result of reporting a genuine concern. We guarantee:

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• Protection from Retaliation: Whistle-blowers will be protected from dismissal, disciplinary action, harassment, or any form of victimization as a result of raising a concern in good faith, even if the concern turns out to be unsubstantiated.

• Good Faith Requirement: Whistle-blowers must have reasonable grounds for their concerns and report them in good faith. Deliberate false allegations or reports made maliciously may result in disciplinary action.

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7. Investigation Process

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All concerns raised under this policy will be investigated thoroughly, promptly, and impartially. The process for investigating a Whistle-blowing report is as follows:

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1. Acknowledgement: The Whistle-blower will receive an acknowledgment of their concern within 14 days of submission.

2. Preliminary Assessment: The Whistle-blowing officer or an appointed investigator will conduct an initial assessment to determine the nature and severity of the concern.

3. Formal Investigation: If the concern warrants further investigation, a formal investigation will be initiated. The Whistle-blower may be asked to provide additional information and will be kept informed of the progress where appropriate.

4. Outcome: Upon conclusion of the investigation, appropriate action will be taken if necessary, and the Whistle-blower will be informed of the outcome, subject to legal and confidentiality constraints.

 

 

8. False Allegations

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While we encourage everyone to report concerns, we expect Whistle-blowers to act responsibly and in good faith. Any individual found to have knowingly made a false or malicious report will face disciplinary action, which may include dismissal or termination of contract.

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9. Monitoring and Review

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The Board of Directors is responsible for overseeing the implementation and effectiveness of this Whistle-blowing Policy. The policy will be reviewed annually to ensure it remains up-to-date with legal and regulatory requirements and continues to foster a culture of openness and accountability.

 

10. Contact Us

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If you have any questions about this policy or wish to report a concern, please contact admin@arafino.com.

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