Whistleblowing and Reporting Concerns
Effective 24, November 2025
Flaxur is committed to operating ethically, lawfully, and in the public interest. We encourage a culture of openness, accountability, and responsibility, where individuals feel confident to raise concerns about serious wrongdoing without fear of retaliation.
This Whistleblowing Policy explains how concerns relating to suspected wrongdoing connected to Flaxur’s activities can be raised and how such concerns will be handled.
1. Purpose of This Policy
The purpose of this policy is to:
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Encourage early reporting of serious concerns.
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Provide safe and clear reporting channels.
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Ensure concerns are assessed and addressed responsibly.
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Protect individuals who raise concerns in good faith.
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Support transparency and accountability across Flaxur’s work.
This policy applies globally to Flaxur’s activities.
2. What Is Whistleblowing?
Whistleblowing is the disclosure of information relating to suspected wrongdoing, malpractice, or dangers that affect the public interest in connection with Flaxur’s activities.
A whistleblower is a person who raises a genuine concern based on reasonable belief that wrongdoing has occurred, is occurring, or may occur.
3. Types of Concerns That Should Be Reported
Concerns that may be raised under this policy include, but are not limited to:
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Fraud, theft, bribery, or corruption.
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Misuse, diversion, or misappropriation of funds or assets.
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Failure to comply with legal or regulatory obligations.
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Procurement, tender, or RFQ irregularities.
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Serious breaches of Flaxur’s policies or ethical standards.
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Abuse of authority or unmanaged conflicts of interest.
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Actions that endanger individuals, programmes, or communities.
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Deliberate concealment of information relating to any of the above.
4. Matters Not Covered by This Policy
This policy is not intended to address:
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Routine service complaints.
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Personal employment grievances (such as disputes about duties, performance, or interpersonal issues), unless they raise issues of public interest.
Such matters should be raised through appropriate complaints or management channels.
5. Who Can Raise a Concern
Concerns may be raised by:
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Staff and volunteers.
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Consultants and contractors.
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Partners, suppliers, and service providers.
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Programme participants.
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Members of the public with relevant information.
There is no requirement to prove wrongdoing. Concerns should be raised where there is a reasonable belief that wrongdoing has occurred or may occur.
6. How to Raise a Concern
Concerns should be raised as early as possible.
Reports may be submitted confidentially by email to:
When raising a concern, it is helpful (though not required) to include:
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A description of the concern.
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Relevant dates, activities, or transactions.
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Roles or functions involved.
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Any supporting information available.
Concerns may be raised anonymously. However, anonymity may limit the ability to investigate fully or provide feedback.
7. Confidentiality and Protection
Flaxur will treat whistleblowing reports sensitively and will take reasonable steps to protect the identity of the whistleblower.
Flaxur does not tolerate retaliation against anyone who raises a concern in good faith. Retaliation includes dismissal, intimidation, harassment, discrimination, or any adverse treatment.
Raising a genuine concern will not result in adverse consequences, even if the concern is not ultimately substantiated.
8. How Concerns Are Handled
All whistleblowing concerns will be:
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Acknowledged where possible.
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Assessed promptly and responsibly.
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Reviewed or investigated proportionately.
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Escalated within Flaxur’s governance framework where appropriate.
Where appropriate and subject to confidentiality and legal considerations, Flaxur will provide feedback to the whistleblower on the outcome of the process.
9. Malicious or Bad-Faith Allegations
Deliberately false, malicious, or reckless allegations may result in appropriate action. This does not apply to concerns raised honestly that are later found to be unsubstantiated.
10. Raising Concerns Externally
This policy does not prevent individuals from raising concerns with appropriate external bodies, regulators, or authorities, particularly where internal reporting has not resolved the matter or where there is a legal obligation to report externally.
Flaxur encourages individuals to seek advice before making external disclosures, where appropriate.
11. Relationship to Other Policies
This policy should be read alongside Flaxur’s:
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Anti-Fraud and Anti-Corruption Policy
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Governance framework
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Compliance approach
12. Review and updates
This Whistleblowing Policy is reviewed periodically to ensure it remains appropriate to Flaxur’s activities and risk profile. The current version will be published on the Flaxur website.