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HAA Policy Document

Whistleblowing Policy

A safe mechanism for reporting suspected wrongdoing, corruption, or serious misconduct at Help African Animals.

Effective: PendingLast reviewed: 2024Version: 1.0Policy owner: HAA Management

1. Purpose

Help African Animals is committed to integrity, accountability and responsible conservation.

This policy provides a safe mechanism for people to report suspected wrongdoing, unlawful conduct, corruption, fraud, abuse of power or other serious misconduct.

2. Who can report

A report may be made by: Staff, Volunteers, Interns, Consultants, Partners, Contractors, Community members, Researchers, or Members of the public.

3. Matters that may be reported

Concerns may include:

  • Fraud, Corruption, Theft or misuse of funds, Financial misconduct, Bribery
  • Conflicts of interest, Abuse of authority, Criminal conduct, Serious breach of law
  • Deliberate concealment of wrongdoing, Serious safeguarding failures
  • Serious research misconduct, Deliberate falsification of conservation information
  • Misuse of HAA resources, Retaliation against a whistleblower

This is consistent with the categories of protected impropriety recognized by Uganda's Whistleblowers Protection Act.

4. Good-faith reporting

Reports should be made honestly and in good faith. A person does not need to prove wrongdoing before reporting a concern, but should provide as much factual information as reasonably possible.

5. How to report

Reports may be submitted through:

  • Email: info@helpafricananimals.org (marked confidential)
  • Written report: Kalungi Plaza, Kampala Road, Uganda
  • Designated Whistleblowing Officer: [Contact to be confirmed]

Where technically possible, HAA will provide an anonymous reporting option.

6. Confidentiality

HAA will make reasonable efforts to protect the identity of a whistleblower.

Information about a report will be shared only with people who need it for assessment, investigation, safeguarding or legal purposes.

The Whistleblowers Protection Act contains specific protections concerning confidentiality of whistleblowers and disclosure information.

7. Protection against retaliation

HAA prohibits retaliation against anyone who makes a good-faith report.

Retaliation may include: Dismissal, Suspension, Demotion, Harassment, Intimidation, Discrimination, Threats, or Unfair adverse treatment.

Ugandan law specifically prohibits victimisation connected with protected disclosures.

8. False or malicious reports

HAA will not take action against someone simply because a concern cannot be substantiated.

However, knowingly making a deliberately false, malicious or fraudulent allegation may constitute misconduct.

9. Assessment and investigation

Reports will be: Received, Recorded securely, Assessed, Assigned to an appropriate person, Investigated where warranted, and Closed with appropriate action.

Where appropriate and legally permissible, the person reporting may receive confirmation that the matter has been reviewed.

10. Conflicts of interest

A person must not investigate a report where they have a conflict of interest.

11. External reporting

Nothing in this policy is intended to prevent a person from exercising rights available under Ugandan law.

The Whistleblowers Protection Act identifies several external institutions to which qualifying disclosures may be made, including the Inspectorate of Government, Directorate of Public Prosecutions, Uganda Human Rights Commission, NEMA and Uganda Police Force.

12. Records

HAA will maintain appropriate confidential records of whistleblowing reports and actions taken, subject to applicable data-protection requirements.