Whistlblower Channel Policy
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Welcome and thank you for visiting CubeIQ Limited ("CIQ") Website (the "Site"). CubeIQ Limited Whistleblower Channel Policy.
CubeIQ Limited Whistleblower Channel Policy
1. Objective
The objective of CubeIQ Limited ("CIQ") Whistleblowing Channel Policy is to set the framework for the Whistleblowing System of which, in addition to its usual reporting channels, can be used to raise any serious concerns, including any suspicion or knowledge of illegal, unethical or irregular conduct.
2. Who can raise concerns?
CIQ Whistleblowing System can be used by the employees, customers, suppliers and other business associates of CIQ.
3. How are concerns raised?
Concerns are raised by accessing the Whistleblowing System on CIQ website. CIQ Whistleblowing System will inform and guide the whistleblower about matters of importance to the assessment of the concern raised.
4. What types of concern can be raised?
- You can use the Whistleblowing System to raise all serious concerns which fall within the scope of the current legislation and regulation regarding protection of whistleblowers.
- Your report should be suspicion or knowledge of any illegal, unethical or irregular conduct, including matters regarding bribery and corruption, fraud, white-collar crime, personal data security violation, serious environmental damage, conflicts of interest, sexual harassment or other gross harassment as well as gross or repeated breaches of law.
- We will specifically assess each case whether the concern is within the scope of the Whistleblowing System. The concern will be within the scope of the Whistleblowing System if it is within the scope of the current legislation and regulation regarding protection of whistleblowers.
- If you are an employee, we note that dissatisfaction with your employment such as salary, position, management style and other contractual terms and conditions are not to be reported to the Whistleblowing System. Instead, such matters are to be addressed through the usual channels either to your supervisor or to department manager or directly with the HR department.
- Concerns must be raised in good faith. In particular, this means that the whistleblowing system may not be used to raise any concerns containing information that the whistleblower knows is wrong.
5. Handling concerns raised
- CIQ has assign the task of Receiving, Monitoring and Handling Reports to one of its employees and one substitute.
- The officer Responsible for Receiving and Monitoring Reports (“RRMR”) will screen every concern raised through the Whistleblowing System.
- The whistleblower will receive confirmation of the receipt of the concern as soon as possible and no later than seven (7) days.
- During the screening RRMR will perform an assessment of the concern. After the assessment of the concern, RRMR will accept or not the concern as capable for investigation.
- If the concern is accepted, then will hereafter be subject of an investigation. The extend of the investigation will depend on the specific circumstances of the concern. The investigation starting point will be carried out by CIQ’s whistleblower entity.
- If the initial screening shows that the concern is not covered by the scope of current legislation and regulation, the concern will not be processed further in the Whistleblowing System, and the whistleblower will be informed accordingly.
- The whistleblower will receive feedback on the status of the concern within 3 months, according to the type of follow-up that has been made, if any.
6. Anonymity and protection of the Whistleblower
- The whistleblower can decide whether to raise the concern anonymously or confidential by giving his/her personal contact details.
- If the whistleblower decides to raise the concern anonymously, neither CIQ nor a third party will generally process the whistleblower's personal data. If, when raising the concern, the whistleblower provides data that make CIQ able to identify the whistleblower, CIQ will, however, be entitled to process such data. This is the case even if the whistleblower has raised the concern anonymously.
- If the whistleblower raises the concern anonymously, the whistleblower will have the option to decide whether he/she wants to be available for any further investigation by setting up a secure and anonymous mailbox through which CIQ can contact the whistleblower. We recommend that the whistleblower sets up a mailbox as it can be difficult for CIQ to conduct an investigation without any further information from the whistleblower.
- If the whistleblower decides to reveal his/her identity when raising a concern, which falls within the scope of the Whistleblowing System, CIQ’s whistleblower entity shall preserve the confidentiality of the whistleblower’s identity in accordance with the applicable rules regarding protection of whistleblowers. Thus, the whistleblower’s identity will only, in principle, be disclosed if the whistleblower explicitly consents to this. The whistleblower’s identity can, however, also be disclosed to public authorities, such as the police or public prosecutor, if deemed necessary to respond to reported matters or for the purpose of ensuring the right to defense for the affected people.
- A whistleblower, who reports serious matters which falls within the scope of the whistleblower legislation and regulation will not face retaliation of any kind as a result of the concern raised.
- The reporting system does not log the IP address or the machine ID of the computer on which the concern is raised, and the system does not use any cookies. If the computer on which the concern is raised is owned by CIQ or connected to the network of CIQ , there is a risk that the IP address and/or the machine ID of the computer from which the concern is raised will be logged in the browser history and/or the security and event logs of CIQ through the logging mechanism that is operated by IT systems of CIQ. The whistleblower can eliminate this risk by raising the concern from a computer that is not owned by CIQ or directly connected to CIQ network.
7. Reporting to external reporting channels
- The whistleblower may also raise a concern through an external reporting channel – i.e. a whistleblowing system which are established by a public authority. Thus, for Greece the Hellenic National Transparency Authority has, for example, established an external reporting channel, which supplements employers’ duty to establish a whistleblowing system.
- Raising a concern through an external reporting channel is not conditioned by a preceding report to CIQ’s Whistleblowing System. However, we encourage you to raise your concern through CIQ’s Whistleblowing System so that CIQ will be able to quickly and immediately follow up on the matter concerned.
Last Reviewed: 2025-04-22