The Hotline operates in accordance with the following principles:

1. Every application received will be verified.
2. The complainant will be protected from harassment and/or other forms of discrimination.
3. On the Whispli platform and app, the applicant has the opportunity to correspond with the reviewer while remaining 100% anonymous.
4. The investigation will involve a narrow range of specialists whose expertise is necessary for verification.
5. The outcome of the review will be communicated to the applicant within the legal provisions of confidentiality.
6. The Hotline and its mechanisms are not a way to settle personal scores.
7. Knowingly making false statements shall be considered a serious offence that may give rise to penalties in accordance with applicable law.
8. The Hotline is not an emergency response service. If you are in danger or in an emergency situation, please call the appropriate services!

• Violation of applicable laws, Code of Ethics and Business Conduct, policies and procedures.
• Any manifestations of corruption (bribes, extortion, improper gifts to public officials, etc.).
• Security threats, discrimination, harassment.
• Violations of labour legislation.
• Violations in the sphere of information security, protection of personal data, confidential and other legally protected information.
• Conflicts of interest (nepotism, provision of services to competitors, abuse of entrusted powers).
• Unfair competition.
• Accounting violations.
• Theft, embezzlement, fraud.
• Violations in procurement activities.
• Money laundering, financing of terrorism.

Employees, third parties, business partners and any other interested person who becomes aware of bribery, corruption, fraud, embezzlement, abuse of authority, harassment or any other violation of the Code of Ethics and Business Conduct may report their suspicions or facts.

The applicant is responsible for the information provided in the application. A report on an alleged violation must be objective and unbiased. It should set out all material information (facts), indicating the grounds for the concern, and provide supporting documents (if any). Filing deliberately false statements is considered a serious offence that may lead to the application of liability measures in accordance with applicable law: such facts, if they contain false information and if there are grounds under applicable law, may be referred to law enforcement authorities.

Any employee, counterparty or other third party claiming in good faith shall not fear termination of employment, demotion, denial of business co-operation, harassment or other forms of discrimination. At the same time, the Applicant may not abuse the protection granted to him/her. The protection afforded to a complainant in the context of an investigation is not a defence against disciplinary or other liability for knowingly making a false report.

The report is submitted via the Whispli independent provider’s website or app. All records of actions taken are protected from deletion and stored on the platform for future audits. Responsible Compliance Officers receive automatic notifications generated by the platform according to the platform settings. The FRHC Compliance Officer oversees the entire process from receipt to reporting.

Within 5 working days from the date of receipt of the inquiry, an employee of the Compliance Service decides whether to accept the inquiry for review, leave it without consideration, or reject the inquiry if there are no signs of violation, unethical or dishonest behavior, or if there is insufficient introductory data. The duration of the further review may vary depending on the scale, risk level, new data, and other factors affecting the course of the investigation, but a response to your inquiry will be provided no later than 60 calendar days from the date of receipt of the inquiry.

In anonymous mode it is impossible to identify the identity of the applicant. Confidentiality (non-disclosure) of the audit and its participants should be ensured at any stage, i.e. if the applicant discloses his/her personal data they will be known only to a narrow circle of persons involved in the audit and will not be disclosed to anyone, not even to the auditors.

Anonymity is only guaranteed if the complainant has contacted Whispli via the Whispli website or app. When registering a message, you can choose either confidential or anonymous mode. You will then need to save the link, your username (usually a fun nickname, such as ‘Jolly Zebra’) and password, as you can then continue communicating with the auditor via a special chat room on the platform or mobile application.