Whistleblowing Policy

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Whistleblowing Policy

Purpose

This policy is established to provide a secure, confidential, and clearly defined process for employees, contractors, and external stakeholders of First Line Software (FLS) to report concerns about unethical behavior, legal violations, and breaches of company policies or security protocols. It aims to ensure that such reports are taken seriously and that the individuals making these reports are protected from retaliation.

Scope

This policy applies to all FLS personnel, including full-time and part-time employees, contractors, consultants, interns, and third-party vendors with access to FLS systems or facilities.

Policy Statement

First Line Software encourages a culture of openness, accountability, and integrity. All employees are empowered to report any activity that appears unethical or illegal, including but not limited to fraud, corruption, data breaches, misuse of assets, and harassment. Whistleblowers may report concerns anonymously. All disclosures will be thoroughly investigated and handled with discretion.

No employee will be subject to retaliation, discrimination, or disciplinary action for making a report in good faith. Any attempt to retaliate against a whistleblower will itself be treated as a serious violation of company policy.

Reporting Mechanisms

First Line Software provides two channels for reporting whistleblowing concerns:

• A secure and confidential email: whistleblowing@firstlinesoftware.com
• An anonymous web form accessible via this LINK
• Direct contact with HR managers (Email, Slack, online or offline meeting)
  
• Employees and other individuals may also report concerns directly to appropriate local authorities, law enforcement, or relevant government agencies, as permitted by applicable law.

Responsibilities

• The HR department is accountable for creating policies and guidelines to prevent possible wrongdoing.
• For further prevention, the HR department is administering training on topics as ethics, compliance, diversity & inclusion. 
• The HR department is responsible for the intake, documentation, and investigation of all reported cases.
• The HR managers ensure fair handling and that appropriate actions are taken. HR managers are not obliged to report any confidential cases to their supervisors.
• The legal department will be supporting the HR department, per request, in specific cases.
• All managers are required to escalate any observed or reported concerns to the HR department without delay.

Investigation process

• Receipt and Logging: 
  
  • Upon receiving a report, the HR Department will promptly (within 7 days) acknowledge the reporter (if not anonymous). 
  • The report will be securely logged, documenting the date received, the nature of the concern, and the initial steps taken in a dedicated secured storage.
  • The reporter will be acknowledged about the investigation status within 3 months from the report date. No investigation details will be shared. 
• Preliminary Review: HR manager will conduct a preliminary review
  
  • Determine if the reported concern is within this Whistleblowing Policy.
  • Assess the seriousness and potential impact of the alleged misconduct.
  • Identify any immediate safety or security risks that need to be addressed.
  • Gather any available information or documentation related to the report.
• Decision on Investigation: Based on the preliminary review, a decision will be made whether to proceed with a formal investigation.

Factors influencing this decision may include:

• The credibility and specificity of the information
• The potential severity of the alleged misconduct
• The availability of sufficient information to warrant an investigation.

The whistleblower will be informed of this decision, where appropriate and permissible, while maintaining confidentiality.

• Planning the Investigation:
  
  • Development of an Investigation Plan: A detailed investigation plan will be developed, outlining the scope of the investigation, the specific allegations to be addressed, the anticipated timelines, the methods to be used for gathering evidence (e.g., interviews, document review, data analysis), and the individuals or departments involved.
  • Preservation of Evidence: Steps will be taken to secure and preserve all relevant information, documents, and electronic data related to the allegations.
•  Conducting the Investigation:
  
  • Gathering Evidence: The investigation will involve a thorough and objective collection of relevant evidence. This may include: Interviews (consider who should be present during the interview), Document Review, Site Visits, Data Analysis
  • Documentation: All steps taken during the investigation, including interviews, evidence gathered, and analysis performed, will be thoroughly documented.
• Findings and Recommendations
  
  • Analysis of Evidence: The HR department will carefully analyze the evidence.
  • Preparation of an Investigation Report: A comprehensive written report will be prepared, summarizing the allegations, the steps taken during the investigation, the key findings, and the conclusions reached. The report will be objective and based on the evidence.
  • Recommendations for Corrective Action: If the investigation substantiates the allegations, the report will include recommendations for appropriate corrective action, which may include disciplinary measures, changes to policies or procedures, training, or other remedial steps.
• Communication and Follow-Up
  
  • Communication of Findings: The findings of the investigation and any planned corrective actions will be communicated to the appropriate individuals within the organization 
  • Feedback to the Whistleblower: Where appropriate and permissible while maintaining confidentiality, the whistleblower may be informed that the report was reviewed and provided with general feedback regarding actions taken or planned. To protect privacy and confidentiality, specific findings, disciplinary actions, employee information, and confidential investigation details will not be disclosed.
  • Implementation of Corrective Actions: The organization will take timely and appropriate action to implement the recommended corrective measures.
• Archiving
  
  • All data to each case will be archived for 5 years from receiving the report (when there is an ongoing court data need to be stored longer).

Measures

We will be tracking the following measures:

• How many reports were submitted
• What topics were reported
• Who was reported for wrongdoing
• The length of time it takes to close and resolve an investigation - Measures effectiveness of policy process

Review 

The whistleblowing policy and the investigation process will be annually reviewed and updated by the HR managers to ensure their effectiveness and compliance with relevant laws and regulations.

Conclusion

This Whistleblowing Policy underscores FLS’s unwavering commitment to fostering a culture of ethical conduct, integrity, and accountability. We believe that providing a safe and confidential channel for reporting concerns is essential for maintaining these values and protecting our stakeholders. 

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By encouraging the reporting of potential wrongdoing, we aim to address issues promptly, learn from them, and continuously improve our operations. We appreciate the vigilance of those who come forward in good faith, and we are dedicated to ensuring that all reports are handled fairly and with the utmost respect. 

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Whistleblowing & Reporting Policy

First Line Software (including the Clinovera brand) Effective from: June 1, 2026

Our Commitment

First Line Software is committed to a culture of openness, accountability, and integrity. We provide a secure, confidential process for reporting concerns about unethical behavior, legal violations, or breaches of company policy, and we protect anyone who reports a concern in good faith from retaliation.

This applies whether the concern comes from someone inside FLS or from a client, partner, or vendor raising a concern about our conduct.

Who Can Report

This policy applies to:

• FLS employees, contractors, consultants, and interns
• Third-party vendors and partners
• Clients and other external stakeholders with a concern about FLS's conduct

What You Can Report

Concerns about fraud, corruption, data breaches, misuse of company assets, harassment, or other unethical or illegal conduct connected to First Line Software.

How to Report

• Email: whistleblowing@firstlinesoftware.com
• Anonymous web form: [link]
• Concerns may also be raised directly with local authorities, law enforcement, or relevant government agencies, where permitted by applicable law.

Reports may be submitted anonymously. All disclosures are handled with discretion and investigated thoroughly.

Protection from Retaliation

No one will face retaliation, discrimination, or disciplinary action for reporting a concern in good faith. Any attempt to retaliate against someone who has made a report is itself treated as a serious violation of company policy.

Confidentiality and Data Protection

Reports are logged and investigated by our HR department under strict confidentiality. Personal data collected as part of a report is handled in accordance with applicable data protection law and is retained only as long as necessary to complete an investigation and meet legal record-keeping requirements.

How Reports Are Handled

Every report is reviewed to determine whether an investigation is warranted, based on the credibility and severity of the concern. Where appropriate, reporters receive confirmation that their report was received and, later, general feedback on the outcome, while specific findings and personnel details remain confidential to protect everyone involved.

This policy is reviewed annually to ensure it remains effective and aligned with applicable laws in the jurisdictions where FLS operates.

For questions about this policy, contact whistleblowing@firstlinesoftware.com.

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