EFFECTIVE DATE: JULY 4, 2024
Whistleblower Policy
A whistleblower as defined by this policy is any employee or external party (such as a vendor, business partner, or contractor) of Atlantic Sapphire who reports an activity deemed illegal or dishonest to one or more of the parties specified in this policy The whistleblower is not responsible for investigating the activity or for determining fault or corrective measures; theseresponsibilities lie with the appropriate management officials.
Examples of illegal or dishonest activities are violations of federal, state or local laws; billing for services not performed or for goods not delivered; and other fraudulent financial reporting.
If an employee or external party has knowledge of or a concern of illegal or dishonest fraudulent activity, they should contact their immediate supervisor or the Human Resources Director. They must exercise sound judgment to avoid baseless allegations. An individual who intentionally files a false report of wrongdoing will be subject to discipline up to and including termination (for employees) or termination of the business relationship (for external parties).
Whistleblower protections are provided in two important areas -- confidentiality and against retaliation. Insofar as possible, the confidentiality of the whistleblower will be maintained. However, identity may have to be disclosed to conduct a thorough investigation, to comply with the law and to provide accused individuals their legal rights of defense. Atlantic Sapphire will not retaliate against a whistleblower. This includes, but is not limited to, protection from retaliation in the form of an adverse employment action such as termination, compensation decreases, or poor work assignments and threats of physical harm.
For External Parties: Negative consequences such as loss of contract, withholding of payment, or other business-related repercussions. Any whistleblower who believes they are being retaliated against must contact the Human Resources Director immediately. The rights of a whistleblower for protection against retaliation does not include immunity for any personal wrongdoing that is alleged and investigated.
Defend Trade Secrets Act (DTSA) Compliance: “Immunity from Liability for Confidential Disclosure of a Trade Secret to the Government or in a Court Filing:
- Immunity—An individual shall not be held criminally or civilly liable under any federal or state trade secret law for the disclosure of a trade secret that—(A) is made—(i) in confidence to a federal, state or local government official, either directly or indirectly, or to an attorney; and (ii) solely for the purpose of reporting or investigating a suspected violation of law; or (B) is made in a complaint or other document filed in a lawsuit or other proceeding, if such filing is made under seal.
- Use of Trade Secret Information in Anti-Retaliation Lawsuit—An individual who files a lawsuit for retaliation by an employer for reporting a suspected violation of law may disclose the trade secret to the attorney of the individual and use the trade secret information in the court proceeding, if the individual—(A) files any document containing the trade secret under seal; and (B) does not disclose the trade secret, except pursuant to court order.”
All concerns received through our company's designated reporting channels, including our company website, will be promptly addressed by the Head of Human Resources. This ensures that all reports are handled in a timely and thorough manner, maintaining the integrity of our reporting process and upholding our commitment to ethical conduct and legal compliance.Employees and/or external parties with any questions regarding this policy should contact the Head of Human Resources.