Operationalizes the Saporina Corporate Policy. Related: Code of Business Conduct, Anti-Bribery Policy, ETI Base Code, Gender Equality Plan, Commitment Against Harassment, CSR Report, Privacy Policy.
1. Purpose
Transparency is the cornerstone of Saporina's reputation. To protect our values, we need to know when they are being compromised. The Responsible Channel (Whistleblowing System) is a secure, confidential mechanism designed to allow employees, partners, and third parties to report irregularities without fear.
This policy aligns with the EU Whistleblower Protection Directive 2019/1937 (opens in a new window), the UK Public Interest Disclosure Act 1998 (PIDA) (opens in a new window), and ISO 37002:2021 (Whistleblowing Management Systems) (opens in a new window). Personal data is processed under GDPR Article 6.1.c (legal obligation) and Article 6.1.f (legitimate interest) — see Section 6.
System Manager: Throughout this policy, the "System Manager" refers to the independent compliance officer designated by the Compliance and Audit Committee to receive, assess, and manage all reports submitted through the Responsible Channel. This individual operates independently of any business unit and reports directly to the Committee.
Service-level commitment: Saporina assigns a named System Manager within five business days of any report, and publishes the role-holder's name and direct contact within 30 days of appointment.
2. Scope
Who can use this channel? The channel is open to anyone with a professional connection to Saporina, including but not limited to:
Internal
Employees, interns, board members, and shareholders.
External
Suppliers, manufacturing partners, logistics providers, contractors, and their respective workers.
3. Reportable Matters
The channel should be used to report actions or omissions that constitute a breach of the law, the Saporina Code of Business Conduct, or our internal policies. This includes, but is not limited to:
3.1 Corruption & Bribery
Kickbacks, improper gifts, or conflicts of interest.
3.2 Human Rights Violations
Forced labor, child labor, or unsafe working conditions in the supply chain.
3.3 Harassment
Sexual harassment, abuse of power, or discrimination.
3.4 Product Safety
Deliberate compromise of food safety standards or food fraud (e.g., falsifying ingredients).
3.5 Financial Irregularities
Fraud, money laundering, or tax evasion.
3.6 Environmental Damage
Illegal dumping or falsification of environmental records.
Note: This channel should not be used for interpersonal disagreements or minor HR grievances unless they constitute harassment or discrimination.
4. Key Guarantees
Saporina is committed to the highest standards of protection for those who speak up.
4.1 Confidentiality
Identity Protection
The identity of the whistleblower will be treated with absolute confidentiality. It will not be disclosed to anyone beyond the authorized System Manager and the investigation team, except where required by law.
4.2 Anonymity
Anonymous Submission Supported
We encourage open reporting, but we fully accept and process anonymous reports. The technical platform ensures that anonymous messages cannot be traced back to the sender.
4.3 Zero Tolerance for Retaliation
Absolute Prohibition
Saporina strictly prohibits retaliation. No one will suffer dismissal, demotion, harassment, or discrimination for submitting a report in good faith. Any attempt to retaliate against a whistleblower is a serious disciplinary offense that may result in termination of employment or cancellation of commercial contracts.
Burden-of-proof shift. Where a worker reports in good faith and subsequently experiences any adverse treatment within 24 months of the report, Saporina presumes the adverse treatment is retaliatory unless the responsible manager can demonstrate, on the balance of evidence, that the action would have been taken regardless of the report. This shift is mandated by Article 21(5) of EU Directive 2019/1937 and aligned with the UK Public Interest Disclosure Act 1998.
4.4 Right to Independent Legal Advice
Support & Advice
In line with Article 21(2) of EU Directive 2019/1937, whistleblowers have the right to consult independent legal counsel and to access support measures before, during, and after submitting a report. Saporina will not consider such consultation a breach of confidentiality and will not penalize a whistleblower for seeking external advice. Trade-union representatives and employee-relations support are also valid points of contact.
5. Procedure
Five-step procedure from submission through resolution. Reports are acknowledged within 7 days and investigations concluded within 3 months.
5.1 Submission
Reports can be submitted 24/7 via:
Web Platform
saporina.com/ethics-channelEncrypted intake form. Allows anonymous two-way communication.
5.2 Acknowledgment
The whistleblower will receive an acknowledgment of receipt within 7 days.
5.3 Initial Assessment
The independent System Manager reviews the report to determine if it falls within the scope of this policy.
- Accepted: An investigation is opened.
- Rejected: The whistleblower is informed of the reasons (e.g., lack of evidence, outside scope).
5.4 Investigation
An internal or external investigator is assigned. The investigation respects the presumption of innocence of the accused party. The investigator gathers facts, interviews witnesses, and secures evidence strictly in accordance with the law.
5.5 Resolution
Saporina commits to concluding investigations within 3 months (extendable to 6 months for complex cases). The whistleblower will be informed of the outcome (e.g., “Violation confirmed and disciplinary action taken,” or “Case closed due to insufficient evidence”).
Progress update at 3 months. If an investigation cannot be concluded within the 3-month period, the whistleblower receives a written progress update at the 3-month mark and a revised timeline. This is required by Article 9(1)(f) of EU Directive 2019/1937.
5.6 Follow-up & Appeal
A whistleblower who is unsatisfied with the outcome may request a written review by the Compliance and Audit Committee within 30 days of receiving the resolution. The Committee’s review is independent of the System Manager and the original investigator.
Where the matter falls within the EU Directive’s scope, the whistleblower’s right to external reporting (Section 8) remains available regardless of the internal-process outcome.
6. Data Protection (GDPR)
All personal data collected through the Responsible Channel is processed in strict compliance with the General Data Protection Regulation (GDPR).
For full details on how Saporina processes personal data, see our Privacy Policy. To exercise data rights, contact privacy@saporina.com.
7. False Reporting
Good-Faith Errors Are Always Protected
If you report a concern sincerely and in good faith, but the investigation determines that no violation occurred, you will not face any disciplinary action. We would rather receive a report that turns out to be unfounded than miss a genuine problem.
Knowingly False Reporting
While we protect good-faith reporting, the channel must not be used to knowingly spread false information or harm colleagues. Malicious or knowingly false reporting is not protected and may lead to disciplinary or legal action against the reporter.
8. External Reporting
Saporina encourages the use of this internal channel as a first step. However, in accordance with the EU Whistleblower Protection Directive, you also have the right to report concerns to competent external authorities if:
Relevant authorities may include: national anti-corruption bodies, labor inspectorates, data protection authorities, financial regulators, or other competent bodies designated under the national transposition of the EU Directive in your jurisdiction. Whistleblowers who report externally in accordance with the Directive receive the same legal protections against retaliation.
For matters arising in Saporina’s Egyptian operations: the Egyptian Administrative Control Authority (ACA), the Public Prosecution, the Egyptian Financial Regulatory Authority (FRA), the Ministry of Manpower’s Labor Inspectorate, and the Personal Data Protection Center are the relevant external bodies depending on the subject matter.