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BP-POL-003

Speak-Up & Whistleblowing Policy

Confidential reporting, fair investigations, feedback and protection from retaliation

Version 1.0Status: Approved2026
Speaking up is a service to Blue Palm. Concerns are heard, handled fairly and protected from retaliation—whether they prove right or not.

Purpose and scope

This policy gives employees, contractors, suppliers and other stakeholders safe routes to raise suspected wrongdoing, risk or concealment. Early reporting allows Blue Palm to protect people, customers and the business, correct problems and cooperate with competent authorities. It applies to Blue Palm personnel and relevant third parties in Federal Iraq, the Kurdistan Region and the UAE/Dubai.

What may be reported

Reportable matters include bribery, fraud, theft, sanctions evasion, money laundering, conflicts of interest or falsified records; child labour, forced labour, trafficking, recruitment fees, passport retention, wage abuse or unsafe working conditions; discrimination, harassment, bullying, violence, retaliation or abuse of authority; food safety, product integrity, substitution, quality, environmental or public-health risks; and breach of law, licence, contract, Blue Palm policy, or deliberate concealment. A personal employment grievance may follow the normal manager or HR route, but this policy may be used where the issue also involves wrongdoing, risk, retaliation, a conflict of interest or a wider public or workforce concern.

Reporting channels

The normal confidential route is the Nominated Compliance Officer, using the dedicated email, telephone or in-person appointment stated in the local reporting notice. Use the Managing Director where the Compliance Officer is involved, unavailable or independence is reasonably believed to be compromised. An independent external adviser may be used when both internal routes are conflicted. Imminent danger, or lawful reporting to an authority, court, regulator, trade union or adviser, must not be delayed by this policy.

How reports are handled

Reports are recorded securely, acknowledged within seven calendar days where contact is possible, and triaged, normally within seven working days. Investigations are scoped fairly, evidence is preserved, relevant people are heard and no conclusion is assumed. Findings are documented, corrective or disciplinary action is taken where appropriate, proportionate feedback is given within three months where lawful, and outcomes are followed up, including retaliation monitoring.

Confidentiality and non-retaliation

Blue Palm will protect the reporter’s identity and information that could reveal it, sharing only with people who need it or where disclosure is required by law. Anonymous concerns are assessed on the available facts. Retaliation—including dismissal, demotion, pay or hours disadvantage, threat, intimidation, harassment, blacklisting, adverse reference or contract loss—is prohibited. A concern that is not substantiated is not, by itself, misconduct; deliberately false or malicious allegations may be addressed through a fair process.

Training, records and review

Induction covers the parts of this policy relevant to each role, with at least annual refresher training for exposed roles. Blue Palm maintains a restricted report register, investigation records and retaliation follow-up. The Nominated Compliance Officer reviews the policy at least annually, after a significant incident, and when relevant law or operations change. Material changes require Managing Director approval.

This webpage is a public-facing presentation of the supplied policy. The downloadable English PDF remains the controlled source for the complete policy, including appendices and internal forms.