1. Purpose
Owl Watch Security Services (OWS) is committed to maintaining the highest standards of ethical conduct, integrity, and compliance with all applicable laws and regulations. This Whistleblower Policy establishes a framework for reporting and addressing concerns regarding suspected misconduct, unethical behaviour, or legal and regulatory breaches within the organisation.
This policy ensures that individuals can report concerns without fear of retaliation and that all
reports are handled promptly, fairly, and confidentially where appropriate.
2. Scope
This policy applies to all directors, officers, employees, contractors, and volunteers of OWS Security Services.
3. Reporting Responsibility
All personnel have a responsibility to report in good faith any concerns regarding:
Violations of OWS policies or code of conduct
Suspected fraud, corruption, or unethical conduct
Breaches of applicable laws or regulations
Improper accounting, internal controls, or auditing practices
Failure to report known or suspected misconduct may itself constitute a breach of company policy.
4. Reporting Channels
OWS encourages an open-door reporting culture. Employees are encouraged to first raise concerns with their immediate supervisor.
Where this is not appropriate or does not resolve the matter, concerns should be escalated as follows:
Senior Management Representative.
The Compliance Officer (formal reporting authority)
All formal whistleblower complaints must be submitted in writing to the Compliance Officer.
5. Compliance Officer Responsibilities
The Compliance Officer is responsible for:
Receiving and documenting all whistleblower reports
Conducting or coordinating impartial investigations
Ensuring appropriate resolution of reported matters
Reporting findings to the General Manager and Managing Director
Providing periodic compliance updates to the Finance Auditor
Where matters relate to accounting or auditing, the Compliance Officer will immediately escalate such issues to the Finance Auditor.
6. Investigation Process
Upon receipt of a complaint, the Compliance Officer will:
Acknowledge receipt of the report where possible
Assess and initiate a timely investigation
Maintain confidentiality to the extent practicable
Determine findings based on available evidence
Recommend and implement corrective or disciplinary actions where appropriate
All investigations will be conducted fairly, objectively, and in accordance with procedural fairness principles.
7. Protection Against Retaliation
OWS strictly prohibits retaliation against any individual who reports concerns in good faith or
participates in an investigation.
Any employee found to have engaged in retaliation will be subject to disciplinary action, which may include termination of employment.
8. Good Faith Reporting
Reports must be made in good faith, based on reasonable grounds. Any deliberately false,
misleading, or malicious allegations may result in disciplinary action.
9. Confidentiality
OWS will treat all whistleblower reports as confidential to the extent possible, consistent with the need to investigate and resolve the matter effectively. Disclosure of information will be limited to individuals directly involved in the investigation and resolution process.
10. Policy Administration
This policy is overseen by senior management and reviewed periodically to ensure ongoing
compliance with legal and regulatory requirements and organisational best practice.
Hasnain Jafri
Managing Director
Owl Watch Security Services