GVC Affiliates Whistleblowing Policy
GVC Services Limited ("GVC") seeks the highest ethical standards in operating its affiliate marketing network (the "Affiliate Network"), and corrupt practices of any sort will not be tolerated. GVC Affiliates is committed to tackling malpractice and it is the personal responsibility of every Affiliate taking part in the Affiliate Network (each an "Affiliate") to manage and reduce the risk of malpractice by our staff, players and other Affiliates.
GVC Affiliates actively encourages Affiliates, where they genuinely believe that malpractice has taken or is taking place, to make protected disclosures directly to GVC Affiliates. Affiliates will be protected where they have reasonable grounds to believe that one of their players, our staff or another third party has committed serious malpractice and make a disclosure in good faith.
This policy sets out the type of disclosure which is protected and also specifies to whom disclosures should be made and the process that will be followed. In order to be protected from disciplinary action for breach of confidence, you should use the Whistleblowing Procedure set out below.
WHAT IS NOT COVERED BY THIS POLICY?
This policy is not intended for personal or individual grievances relating to your participation in the Affiliate Network. In such cases you should contact your Affiliate Manager at first instance.
WHAT CONCERNS SHOULD BE RAISED?
You should raise a concern as soon as possible if you become aware of a situation or matter which you reasonably believe might show any of the following malpractices:
- A criminal offence, such as theft, fraud, bribery or collusion.
- Danger to the health and safety of any individual
- Failure to comply with applicable legal and contractual obligations
- A miscarriage of justice
- The deliberate concealment of information about any of the above
- Wherever possible the Affiliate's identity will not be disclosed without their specific permission or unless there are grounds to believe that they have acted maliciously. However, should the disclosure result in court proceedings your identity may need to be revealed to a Court of competent jurisdiction.
- There will be no victimisation of any Affiliate for making a disclosure or providing information in respect of a disclosure.
- Any disclosure that is not upheld but is made in good faith will not be cause for action against the Affiliate.
- Any abuse of this procedure by raising deliberately false, unfounded or malicious allegation or by making an external disclosure in breach of this policy without reasonable grounds or otherwise than to an appropriate authority, may result in the termination of your affiliate agreement.
- At any time during the process you may seek support and advice from your Affiliate Manager by emailing email@example.com.
THE PROCEDURE TO RAISE A CONCERN
1. Informing GVC Affiliates
Send an email to our secure and confidential mail box: firstname.lastname@example.org. The mailbox is directed independently of the GVC Affiliates team to a senior member of the GVC Group who will investigate the disclosure. Alternatively, should you wish to speak with someone directly, you may call your Affiliate Manager.
You may make the disclosure anonymously; however, you are encouraged not to do this as it may inhibit any proper investigation.
2. The first meeting
You will be contacted to arrange a meeting which will usually be by telephone and held within 5 business days. The meeting will be held with a senior member of the investigation team.
The purpose of this meeting is for you to provide further details and demonstrate you have reasonable grounds for believing serious malpractice has taken place.
A written summary of the meeting will be prepared and sent to you via email and should be signed by you and the investigating officer/s. This document will be treated as strictly confidential.
3. The investigation
Where appropriate, further investigation will then be carried out by the investigating officers. You will be kept informed of progress and may be required to attend additional investigatory meetings by telephone or provide further information by email.
4. Reporting the outcome
Following investigation, a report will be prepared for the GVC Group's Board of Directors detailing the findings and any subsequent actions.
You will be notified in writing of the outcome of the investigation and the resulting action that has been taken.
5. Disclosure to an external body
If you feel any malpractice has not been adequately dealt with, you should inform your Affiliate Manager in writing that you intend to make a disclosure to an external body.
Provided you are acting in good faith and you have evidence to back up your concerns, you can also contact:
- The Gibraltar Regulatory Authority
31st May 2018