nealthy - digital asset management

Whistleblowing Policy

Version: 1.0
Last revised: 13. November 2023

1. Policy Statement

nealthy (hereinafter referred to as the Company) takes seriously any valid and non-malicious disclosure of a failing within the company, either by the company itself through operational failings or by any staff member or associated individual.

nealthy supports all staff and encourages an open and transparent workplace where employees feel safe to report any concerns that they may have. When a person reports a concern and advises that the disclosure has been made under the firm's Whistleblowing Policy, we will take every measure to ensure that the staff members’ identity is protected and that they are treated in a fair and confidential manner. 

The Company complies with all applicable local laws and regulations within the UAE and international best practices, and adopts a positive approach towards staff reporting any potential or suspected wrong doings as they apply to legislative, regulatory or statutory requirements. 

This policy provides further information on our intent in this area and contains guidance for staff on reporting any such wrongdoing and assurances as to the confidentiality of any report. 

2. Purpose

The purpose of this policy is to provide the Company’s intent and approach with regards to complying with all applicable local laws and regulations within the UAE and international best practices, and our own internal Whistleblower Policy and procedures. The policy is designed to deal with any concern raised in relation to issues which are in the public interest and are not already covered within the Company’s existing policies and procedures. 

We maintain a transparent and open workplace where all staff are encouraged to report any suspicions or concerns to the compliance officer (via the Whistleblowing Complaint Form) without fear of recrimination or further consequences. All such reports are held in the strictest confidence and reporting staff will be treated with due consideration and respect.


This policy applies to the Company and its staff (meaning permanent, fixed term, and temporary staff, any third-party representatives or sub-contractors, agency workers, volunteers, interns and agents engaged with the Company). Any member of staff who does not follow this policy and any associated procedures will be subject to disciplinary procedures and possible termination from the company.

4. What is Whistleblowing?

For the purposes of this policy, ‘whistleblowing’ refers to any individual who has become aware of an illegal activity taking place in or in association with the Company and the act of sharing this information with another person, authority or regulator, for the purposes of reporting it.

The person doing the reporting is known by the term ‘whistleblower’. This person can be an employee, contractor, agent, client, supplier or any other third party associated with the Company. Despite the stigma surrounding the term ‘whistleblowing’, the Company views this act in a positive light and will work to protect the identity and reputation of any person who comes forward to report actual or suspected illegal activities.

5. Who Can Raise a Concern?

Any member of staff who has reasonable belief of a qualifying disclosure can raise and/or report a concern. A qualifying disclosure is information about malpractice, which includes, but is not limited to: 

  • Fraud, corruption and bribery;
  • Profiting from confidential information in trading or other income generating activity; 
  • Disclosure or leak of restricted information; 
  • Unfair nepotism of a particular financial institution or contractor;
  • Overstepping official delegation of authority to achieve a private gain; 
  • Failure to abide by legal and regulatory obligations;
  • Endangering health and safety;
  • Covering up wrongdoing

Disclosures must not be made for purposes of personal gain and the policy does not apply to personal grievances regarding:

  • An employee’s terms and conditions of employment
  • Any aspect of the working relationship
  • Complaints of bullying or harassment
  • Disciplinary matters 

6. Objectives

It is the Company’s aim to ensure that:

  • All staff are made aware of their rights in relation to Whistleblowing;
  • All staff are made aware of any verbal or written procedures and guidance that we have in place and how they apply to them and their role;
  • All staff are aware that any concerns or suspicions of wrongdoing are to be reported immediately and that any such report will not purport any negative consequences or detrimental treatment within the workplace by any other staff member
  • Staff are made aware of alternate reporting lines (i.e. COO), should they wish not to disclose their concern to the compliance officer;
  • Staff are made aware that any false or malicious reports will be penalised by the firm and disciplinary action will be taken;
  • All staff are protected from victimisation, harassment or disciplinary action as a result of any disclosure.

The whistleblower should make it clear that they are making their disclosure within the terms of this whistleblowing policy, which ensures that the recipient of the disclosed information realises this and takes the necessary action to investigate the disclosure and to protect the whistleblower's identity. 

7. Whistleblower Protection & Rights

The Company takes any suggestion or report of illegal activity associated with the company very seriously and will always carry out a full investigation into any allegations. This policy aims to protect any employee who makes a disclosure about certain matters of concern, when those disclosures are made in good faith. We will also ensure that any employee who makes a disclosure under this policy is supported and protected against harassment and/or victimisation.

The Company does not tolerate any harassment or victimisation of a whistleblower (including informal pressures, suggestions or remarks) and will take appropriate action to protect any employee who raises a concern in good faith. Any employee found to be the cause of harassment or victimisation will be considered to have committed a serious disciplinary offence and will be dealt with under our disciplinary rules and procedures.

All concerns will be treated in confidence and every effort will be made not to reveal the identity of the disclosing employee if they so wish. We also support the act of making disclosures anonymously if an employee feels this is their only option, however we would encourage any employee to put their name to any allegation where possible so that a follow up and proper investigation can be conducted. If an employee chooses to make an anonymous report, he or she must provide sufficient information about the basis of the allegations, along with appropriate details or supporting evidence, to allow the matter to be responsibly investigated, otherwise, it may not be possible to proceed with an investigation.

8. Procedure

The Company ensures that all staff are aware of the Whistleblowing Policy and Procedures and are provided with access to the Whistleblowing Incident form and reporting lines. Any employee wishing to raise a concern, is asked to follow the below process.

8.1 Raising a Concern

8.2 Non-Whistleblowing Complaints

Where the assigned investigator deems the complaint to be dealt with under an alternate company procedure (e.g. general complaint procedure, grievance procedure), they will advise the person making the disclosure as to the appropriate steps to follow.

9. Whistleblowing Complaints

Where the investigator considers the complaint to be subject to the Whistleblowing Procedures, the complaint assessment process is followed, and the investigator decides whether the matter raised should be: -

  • Investigated internally
  • Referred to an external auditor
  • Referred for independent enquiry
  • Reported to the authorities and/or regulating body

10. Complaint Assessment

All Whistleblowing Complaint Forms are automatically sent to the Compliance Officer who is responsible for:

  • Investigating the concern raised;
  • Decide if the complaint should be dealt with under the Whistleblowing Procedure;
  • Gathering additional and/or supporting information;
  • Informing relevant stakeholders and/or external parties;
  • Deciding the outcome of the concern

Where the investigator decides not to proceed with an investigation or that no outcome actions are required after reviewing the complaint details; this decision is explained fully to the individual who raised the concern. 

The individual is then advised that if they disagree with the decision not to proceed, they may report the incident again to the Chief Operating Officer.

11. Investigation Outcome

Where the complaint is upheld, the investigator will complete the Whistleblowing Complaint Form with the review outcome and advise of the next steps to be taken. Where the incident is dealt with internally, resulting actions are recorded on the form and any formal disciplinary actions (if applicable) are noted.

12. Feedback and Reporting

The Company will always provide feedback to a whistleblower about a reportable concern where it is feasible and appropriate to do so. However, we will ensure the confidentiality of the investigation is maintained at all times.

Completed whistleblowing complaint forms along with all information and evidence gathered during a whistleblowing investigation, including outcomes are maintained by the company for a period of 8 years after the complaint date. 

The person appointed to oversee the whistleblowing procedures will provide an annual report to the Board along with senior management. This report will detail investigations and outcomes as well as the operation and effectiveness of any systems and controls related to whistleblowing.

13. Training and Development

The Company has a robust and extensive induction program for all new starters that includes access to essential policies such as the Whistleblowing Policy so that all employees know what their rights and responsibilities are.

We provide reminders to all staff via the relevant Slack channel in reviewing the Whistleblowing Policy. The reminder covers:

  • a statement that the firm takes the making of reportable concerns seriously;
  • examples of events that might prompt the making of a reportable concern;
  • examples of actions that might be taken by the firm after receiving a reportable concern;
  • measures taken to protect the whistleblower’s confidentiality and identity;
  • recognising when there has been a disclosure of a reportable concern by a whistleblower;
  • providing feedback to a whistleblower (where appropriate).

14. Responsibilities

It is the responsibility of all employees to ensure that this policy is understood and complied with by all staff and that the supplementing procedures and reporting lines are also made clear and are available for reference. Failure to comply with this policy may lead to disciplinary action being taken.