Whistleblower Policy

1. Objective

The purpose of this policy is to provide a clear, confidential, and secure mechanism for anyone connected with the organization to report in good faith any wrongdoing, illegal activity, or activity that is contrary to the organization's values ​​and policies. It aims to foster a culture of integrity, transparency, and accountability, and to ensure that any misconduct is identified and corrected promptly.

2. Scope

This policy applies to all employees, managers, executives, board members, suppliers, subcontractors and business partners.

3. Definitions

  • Whistleblower : any person who, in good faith, reports misconduct or a problematic situation.

  • Reporting : The act of communicating information regarding an activity that is illegal, unethical, fraudulent, or non-compliant with applicable laws and policies.

  • Retaliation : Any negative or punitive action taken against a whistleblower as a result of reporting.

  • Grievance : A formal complaint or report submitted under this policy.

4. Situations that may be subject to reporting

Without limitation, the following situations may be reported:

  • Fraud, theft, corruption or misuse of organizational property.

  • Harassment, intimidation, discrimination or violation of fundamental rights.

  • Non-compliance with environmental laws, regulations or obligations.

  • Serious breaches of internal policies, the code of ethics or contractual obligations.

  • Any activity that endangers the health, safety, integrity of a person or the environment.

5. Reporting mechanisms

Reports can be made through the following channels:

  • Confidential email to celine@kotmo.ca

  • Confidential meeting with the Compliance Officer, Human Resources or other designated person.

Reports can be made anonymously, although identification may assist in the investigation.

6. Steps for processing a report or grievance

  1. Acknowledgment of receipt
     An acknowledgment of receipt is sent to the whistleblower within 5 working days following receipt of the report (unless it is anonymous).

  2. Preliminary analysis
     An initial assessment is carried out to determine whether the grievance is admissible and falls within the scope of this policy. This step must be completed within approximately 10 working days .
     If the report is deemed invalid or not relevant, a written justification will be provided to the person who submitted it (to the extent their identity is known).

  3. Investigation
     If the report is deemed admissible, an impartial investigation is opened by the designated official or by an independent third party.
     The investigation aims to collect facts, analyze evidence and assess the seriousness of the situation.
    This step should ideally be completed within 30 working days , or longer if the complexity of the file requires it.

  4. Decision and corrective measures
     The results of the survey are evaluated by management or the designated committee.
     Corrective measures are implemented, where appropriate, and communicated to the whistleblower where possible.
     If no breach is found, a clear justification is provided to the person who submitted the grievance.

  5. Closing the file
     A complete file is recorded, including the nature of the report, the steps followed, the timeframes, the conclusions and the actions taken.

7. Protection against retaliation

  • No employee or partner will be retaliated against for making a report in good faith.

  • Retaliation is a serious violation of this policy and will result in disciplinary action up to and including termination of employment or termination of employment.

8. Confidentiality

  • The whistleblower's identity will be protected and will remain confidential, unless required by law to be disclosed.

  • Information related to the investigation will be shared only with those whose intervention is necessary.

9. Responsibilities of the organization

The organization undertakes to:

  • Ensure a working environment where reports can be made safely.

  • Raise awareness and regularly train employees and managers on this policy.

  • Respect processing deadlines and provide reasoned responses to complainants.

  • Periodically review the policy to ensure its relevance and effectiveness.

10. Entry into force and revision

This policy is effective from October 1, 2024. It will be reviewed every two years, or more frequently if necessary, to reflect evolving best practices and applicable legal requirements.