Whistleblowing Policy
Last updated: August 2025
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Table of Contents
- Introduction
- Definition of Terms
- Purpose
- Objectives of the Policy
- Scope of Policy
- Whistleblowing Procedure
- Time Limit for Investigation
- Protection of Whistleblowers
- Documentation and Record Keeping
- Introduction
The Institute for African Research and Innovation (iARAi) is committed to maintaining the highest standards of integrity, transparency, and ethical conduct in all research, policy, and innovation activities. This Whistleblowing Policy (the “Policy”) establishes a framework to encourage employees, researchers, partners, and other stakeholders to report suspected misconduct or breaches of law, regulations, or iARAi’s internal policies without fear of retaliation. The Policy ensures that concerns are addressed promptly, fairly, and confidentially to uphold iARAi’s mission of driving sustainable development through research and innovation.
- Definition of Terms
For the purposes of this Policy, the following definitions apply:
- Board: The Board of Directors of iARAi.
- Director: A member of the Board.
- Appropriate Authority: The line manager of the whistleblower, or the next senior officer if the line manager is conflicted or implicated in the reported concern.
- Employee(s): Includes full-time staff, contract staff, researchers, consultants, and other individuals working for or with iARAi.
- Good Faith: A report made without malice or personal gain, based on a reasonable belief that the concern is true. A report does not need to be proven true to be made in good faith but must not be knowingly malicious or false.
- Investigation: A structured process to gather and analyse information to determine whether misconduct has occurred and identify responsible parties.
- Suspect: An individual alleged to have committed misconduct, subject to investigation.
- Detrimental Treatment: Any form of victimisation or reprisal against a whistleblower, including dismissal, undue influence, withholding of benefits, or any act negatively impacting the whistleblower.
- Whistleblower: Any person, including employees, directors, or stakeholders, who reports unethical behaviour, misconduct, or dishonesty to the appropriate authority.
- Purpose
The purpose of this Policy is to create a safe and transparent environment where employees, researchers, and stakeholders can raise concerns about suspected malpractice, unethical conduct, or illegal activities within iARAi’s operations. The Policy aims to ensure that such concerns are reported, investigated, and resolved appropriately to safeguard iARAi’s mission and reputation.
- Objectives of the Policy
The Policy seeks to:
- Foster a culture where employees and stakeholders can report concerns about misconduct, irregularities, or malpractice responsibly and without fear of harassment or victimisation.
- Provide clear procedures for reporting and handling concerns.
- Encourage timely reporting of suspected fraud, misconduct, or risks, ensuring confidentiality and protection for whistleblowers.
- Reassure whistleblowers that genuine concerns, even if mistaken, will not lead to reprisals.
- Scope of Policy
This Policy applies to all iARAi employees, researchers, contractors, consultants, and stakeholders involved in its activities across the world. It covers reportable misconduct, including but not limited to:
- Fraud or financial irregularities.
- Criminal activities.
- Health and safety risks to employees, stakeholders, or the public.
- Environmental hazards or pollution risks.
- Breaches of legal, professional, or regulatory obligations.
- Bribery or corruption in violation of applicable laws or iARAi’s policies.
- Breaches of iARAi’s internal policies and procedures.
- Conduct likely to damage iARAi’s reputation.
- Misuse or theft of iARAi’s assets or resources.
- Abuse of authority or conflicts of interest.
- Unauthorised disclosure of confidential information.
- Forgery or falsification of documents.
- Deliberate concealment of malpractice.
Concerns must be based on factual knowledge, not speculation, rumours, or gossip. Reports can be made confidentially and anonymously via:
- Email: whistleblowing@theiarai.org
This Policy does not cover individual grievances related to job performance or employment terms, which are managed by iARAi’s Human Resources Department.
- Whistleblowing Procedure
This section outlines the process for reporting concerns and ensures whistleblowers are protected from repercussions.
6.1 Confidentiality
iARAi encourages open reporting but respects requests for confidentiality. If a whistleblower wishes to remain anonymous, iARAi will protect their identity to the fullest extent possible. If the investigation requires disclosing the whistleblower’s identity, iARAi will seek their consent beforehand. Without consent, the identity will not be disclosed. Whistleblowers are encouraged to provide detailed information to aid investigations, including:
- Nature of the incident.
- Individuals involved.
- Date(s) and place of occurrence.
- How the incident occurred.
- Any additional relevant details.
If a whistleblower’s identity is accidentally disclosed, iARAi will take steps to maintain confidentiality.
6.2 Reporting a Concern
Employees are encouraged to raise concerns with their line manager, either in person or in writing. If the concern involves the line manager, is deemed serious, or the whistleblower believes the manager will not handle it adequately, they should use the designated whistleblowing channels (see Section 5). When reporting, whistleblowers must:
- Act in good faith.
- Have a reasonable belief that the concern is true.
- Avoid malicious or false allegations.
- Not seek personal gain from the report.
6.3 Investigation Process
Upon receiving a concern, the Human Resources Manager (HRM) will:
- Acknowledge receipt within 3 working days (excluding weekends).
- Conduct a preliminary review to determine if the concern falls within the scope of reportable misconduct.
The preliminary review aims to:
- Confirm whether a wrongdoing has occurred and its extent.
- Prevent further misconduct, asset loss, or reputational damage.
- Protect evidence sources.
If the concern qualifies as a reportable misconduct, a formal investigation will be initiated. If not, the matter will be referred to the appropriate authority. In cases of criminal activity, the HRM will report to relevant law enforcement and, if necessary, pursue legal action. Upon investigation completion, relevant departments (e.g., Human Resources, Legal, or Finance) will take action in line with iARAi’s policies. If dissatisfied with the outcome, the whistleblower may escalate the matter to the Board Audit Committee Chairperson, without prejudice to their right to seek legal redress.
- Time Limit for Investigation
iARAi is committed to resolving concerns promptly. Investigations should conclude within four weeks. If this timeframe is exceeded, the HRM must notify management and the Board Audit Committee Chairperson, providing reasons for the delay and an updated timeline.
- Protection of Whistleblowers
iARAi recognises that whistleblowers may fear repercussions. The organisation will protect whistleblowers from detrimental treatment, including dismissal, disciplinary action, or other adverse consequences, even if their concerns are mistaken but made in good faith. Any whistleblower experiencing victimisation should report to the Human Resources Manager, Chief Operating Officer, or Chief Executive Officer. iARAi will investigate such claims and take disciplinary action against those responsible for retaliation, which may include summary dismissal.
- Documentation and Record Keeping
The HRM will maintain a secure register of all whistleblowing concerns, updated quarterly and reported to the Board. The register will include:
- A summary of reported cases.
- Whether an investigation was conducted.
- The investigation process and findings.
- Actions taken as a result.
Records will be stored confidentially in compliance with data protection regulations.