Whistleblower Policy

Last Updated:  August 10, 2023
Last Reviewed:  August 10, 2023

 

Introduction

Wingu Technology LLC (the “Company”) is committed to maintaining the highest standards of integrity, ethics, and accountability in all aspects of its business. This Whistleblower Policy aims to provide employees, contractors, vendors, customers, and other stakeholders with a confidential and secure platform to report any concerns regarding unethical behavior, illegal activities, or violations of the Company’s policies.

Purpose

The purpose of this Whistleblower Policy is to encourage individuals to report any genuine concerns they may have about potential wrongdoing within the Company, without fear of retaliation. This policy sets out the procedures for reporting, investigating, and resolving such concerns.

Scope

This policy applies to all employees, contractors, vendors, customers, and any other individuals associated with Wingu Technology LLC. It covers all aspects of the Company’s operations, including but not limited to financial matters, accounting practices, data privacy, safety, harassment, discrimination, and any violation of laws or regulations.

Reporting Channels

The Company encourages individuals to report concerns through appropriate channels to ensure confidentiality and impartiality:

a. Reporting to Immediate Supervisor: Employees and contractors are encouraged to report concerns directly to their immediate supervisor.

b. Anonymous Reporting: For those who wish to remain anonymous, the Company has established an anonymous reporting system through [designated method, such as a dedicated email address or third-party reporting platform]. The identity of the whistleblower will be kept confidential to the extent permitted by law.

c. Reporting to Senior Management: If the concern involves the immediate supervisor or the whistleblower feels uncomfortable reporting through regular channels, they may report directly to senior management or the designated ethics officer.

Whistleblower Protection

The Company strictly prohibits retaliation against any individual who reports a concern in good faith. Whistleblowers who raise legitimate concerns will be protected from any adverse actions, including but not limited to termination, demotion, harassment, or discrimination.

Investigation Process

Upon receipt of a report, the Company will promptly and impartially investigate all concerns. The investigation will be conducted by a designated individual or committee, ensuring confidentiality to the extent possible.

Non-Retaliation Policy

Any attempt to retaliate against a whistleblower will be treated as a severe violation of this policy and will result in disciplinary action, up to and including termination.

False Accusations

Making false or malicious allegations knowingly will be considered a serious offense and may result in appropriate disciplinary action.

Confidentiality

The Company will treat all reports and investigations with the utmost confidentiality, consistent with applicable laws and regulations.

Compliance

All employees, contractors, and stakeholders are required to cooperate fully with the investigation process and comply with the terms of this Whistleblower Policy.

Review and Amendment

This policy will be periodically reviewed and updated to ensure its effectiveness and compliance with changing laws and best practices.

Wingu Technology LLC is committed to upholding the highest standards of ethics, integrity, and transparency. This Whistleblower Policy aims to encourage a culture of openness and accountability, allowing individuals to report concerns without fear of retaliation. By following this policy, we aim to foster a safe and ethical work environment for all stakeholders.