Whistleblower Policy
Introduction
1.1 Any modern and diverse organisation faces a wide range of risks, including incidents that may adversely affect the company’s reputation, financial assets, operational efficiency, and the overall welfare of its employees. These incidents may include, but are not limited to, criminal activity, fraud (i.e., attempts to gain benefits through dishonesty, deception, bribery, or conflicts of interest), trafficking, intentional or negligent damage to property, ongoing breaches of human rights laws, or individual violations such as discrimination, harassment, or workplace misconduct. Such incidents may arise from improper behaviour, non-compliance with organisational policies, or deliberate violations of legal or regulatory requirements. Managing these risks effectively is crucial to protect the organisation, its employees, stakeholders, and the communities in which it operates.
1.2 DP World Group (the Group) is fully committed to conducting its business in accordance with the highest standards of honesty, ethical conduct, and integrity. To support this commitment, DP World has implemented a globally accessible whistleblowing hotline and reporting mechanism. This mechanism provides all stakeholders, including employees, contractors, suppliers, partners, and other relevant parties, with a free, confidential, and secure way to report concerns, irregularities, or suspected wrongdoing. The reporting mechanism is designed to ensure accessibility, impartiality, and protection of individuals who raise genuine concerns, enabling the Group to act promptly and appropriately in response to such reports.
Purpose
2.1 The purpose of this policy is to provide stakeholders with a clear framework for reporting suspected misconduct, fraud, unethical practices, or other wrongdoing. It aims to provide guidance, communication channels, and the confidence necessary for stakeholders to report genuine concerns in a timely and responsible manner. In line with the procedures outlined in this policy, all reported matters will be investigated thoroughly, objectively, and confidentially. The identity of the whistleblower will be protected wherever possible, and retaliation against individuals who report concerns in good faith is strictly prohibited.
2.2 This policy is based on the presumption that all reports are made honestly, with genuine intent, and in good faith. Reports that are malicious, reckless, or intended for personal gain will not be tolerated and may lead to disciplinary action under DP World’s internal procedures, or to legal consequences as applicable. Stakeholders are encouraged to carefully consider the accuracy and intent of their reports before submission.
2.3 In instances where concerns involve personal employment or Human Resources matters, such as workplace grievances, interpersonal conflicts, or other employment-related issues, employees should refer to their local DP World Employee Handbook. This handbook provides detailed procedures and steps to ensure that such matters are addressed appropriately, in line with local policies and legal requirements.
2.4 For the purposes of this policy, key terms such as ‘whistleblowing,’ ‘whistleblower,’ and other relevant terminology are defined in Section “Definitions and Terms” herein. Understanding these definitions is essential to ensure consistent application of the policy, to protect whistleblowers, and to uphold the Group’s commitment to integrity, transparency, and accountability in all business operations.
2.5 By implementing this policy, DP World seeks to foster a culture of openness, responsibility, and ethical behaviour throughout its operations. All employees and stakeholders are encouraged to act with integrity, raise genuine concerns when observed, and contribute to creating a safe, fair, and compliant work environment.
Scope
Scope
3.1 This policy applies to all stakeholders associated with the organisation, including but not limited to employees, management, contractors, suppliers, consultants, and any other parties who engage with or act on behalf of the business. It is intended to provide clear guidance on expected standards of conduct and compliance across all areas of operation. In the interest of transparency and accountability, this policy is made publicly available and can be accessed on both the organisation’s intranet and internet platforms.
3.2 We strongly encourage the adoption and application of this policy by all business partners, collaborators, and joint ventures in which DP World holds a minority shareholding. While recognising that we may not have controlling interest in such entities, we advocate for the alignment of practices and principles with those outlined in this policy to promote consistency, ethical conduct, and responsible business practices across all associated operations.
Policy
Reporting Information:
4.1 In line with DP world’s Fraud policy and Code of Ethics, all employees are required to act honestly and always with the highest levels of integrity and ethics when conducting business for the Group. They also have the responsibility to report any policy breach, any suspected fraud or any other wrongdoing in a timely manner to the appropriate team or to the Head of Fraud Risk Services.
4.2 In turn, Management is expected to be alert, recognise risks, be aware of indicators of wrongdoing or corrupt acts, respond to any sign or report of such, whilst ensuring the confidentiality and protection procedures outlined in this policy.
4.3 All persons are strongly encouraged to report any concerns as directed, in as much detail as possible, in line with this policy. Since it is likely the concerns relate to the conduct of DP World staff, and therefore might present a difficult and personal conflict for the informant, there are multiple methods of reporting available.
Reporting Mechanisms:
4.4 The following methods are available:
Whistleblowing Hotline – DP World Website (Internet)
If you have witnessed any corruption or wrongdoing that affects DP World business, or may violate laws, particularly including with respect to Human Rights violations, Human Trafficking, drugs, contraband, Illegal Wildlife Trafficking (IWT) or any other form of trafficking, and you are unable or unwilling to take this problem (if you are an employee) to your line manager, you can contact, 24/7, the secure Whistleblowing hotline in complete confidence via the links found in company websites. These links give you the option of choosing the preferred language for your report. All reported information is treated in the strictest confidence and will be investigated by the appropriate team. Informants can remain anonymous, and the external provider will not identify them to DP World if requested.
Whistleblowing Hotline – Intranet
The global Connexions intranet, and most of the local or regional intranets of subsidiaries and associates, provide links to the same reporting website as above.
Phone Reports to the hotline can be made in many countries where DP World has a presence by dialling a freephone number and speaking to an operator, in most cases in the whistleblower’s preferred language. The number is displayed on posters on company premises and in intranets and websites.
Letter Please write your information in a detailed letter and send to:
DP World
Group Internal Audit Department Attention: Head of Fraud Risk Services PO Box 17000
Jebel Ali Free Zone Dubai, UAE
Direct Reporting
All staff have the option of reporting direct to their respective business unit line manager, or please approach the Head of Fraud Risk Services or a member of the Fraud Risk Services Team within Group
Internal Audit at:
Group Internal Audit Department
4th Floor, Building 17
DP World
Jebel Ali Free Zone
Dubai, UAE
Protection/Confidentiality:
4.5 This policy is written with all the provisions for confidential and anonymous reporting, as it is important for staff to feel secure in this reporting environment. Subject to country laws, whistleblowers have the option to remain anonymous or to identify themselves.
4.6 Any report or information received through the above mechanisms will be kept confidential, and any details pertaining to any possible matter of fraud or other wrongdoing, will only be conveyed to those people who require the knowledge in the proper performance of their office or function.
4.7 It is globally understood that ‘whistleblowers’ can be negatively portrayed as someone who is ‘informing on their own’, is a ‘spy’, or that they might be revealing information that has significant and serious repercussions for the accused. As such, they might be fearful for reporting information in the worry of being subject to repercussions and retaliation such as intimidation, harassment, dismissal or even violence from their colleagues or superiors. DP World acknowledges this concern and will not tolerate retaliation of any kind relating to informing parties. They will also support staff who raise genuine concerns in good faith under this policy, even if the information is not established as a fraud or other wrongdoing. Staff must be assured that they will not be victimised or disadvantaged in reporting a breach and any person who considers they are being victimised or disadvantaged because of such reporting, should in the first instance contact the Head of Fraud Risk Services.
4.8 Where evidence is found to suggest that efforts had been undertaken by any other person, to identify the reporting party of ‘whistleblowing’ information, that person will be subject to disciplinary action, as deemed appropriate.
4.9 If any reporting party believes they have become the subject of any retaliation, they are entitled to submit a formal retaliation complaint. This should be made within 6 months of the initial retaliation, or if multiple occasions, within 6 months of the last incident and will be investigated by the relevant People Department.
Investigation:
4.10 Strict confidentiality and objectivity concerning the complainant and the information will be maintained at all stages of the investigation, in accordance with the Fraud Risk Services Procedures Manual.
4.11 Information reports will be individually categorized depending on the information received and the level of fraud or other wrongdoing identified. All reports will initially be investigated by the Fraud Risk Services team or delegated personnel. The outcome and any recommendations for actions will be documented in accordance with the Fraud Management Framework.
4.12 Feedback on the investigation outcome may be given to the complainant, but only if contact details are provided to Fraud Risk Services. However, DP World cannot guarantee the outcome of the investigation is the result the whistle-blower might be seeking, nor does it undertake to provide a report to the whistleblower beyond confirmation that a conclusion was reached
4.13 For further clarity on fraud information reporting and investigations, please refer to DP World Fraud Policy.
Records and Monitoring:
4.14 DP World Fraud Risk Services shall retain all records relating to the reports for a period in accordance with company document retention policies and/or country laws as applicable. Access to these records is strictly restricted to authorised management and staff under the guidance of the Head of Fraud Ris Services and relevant authorities.
4.15 The performance of the whistleblowing hotline is overseen by the DP World Audit and Risk Committee through regular reporting.
Policy Administration:
4.16 The Head of Fraud Risk Services is responsible for the policy administration, and its review annually, with approval by the DP World Audit and Risk Committee.
Related Standards, Policies and Processes
Related Standards, Policies and Processes
5.1 This policy should be read and understood in conjunction with a range of related corporate standards, policies, and processes that collectively govern ethical conduct, compliance, and responsible business practices across the organisation. These supporting documents provide additional guidance and detail to ensure consistent application of our values and obligations in all areas of operation.
The relevant policies include, but are not limited to:
DP World Global Fraud Policy
DP World Anti-Bribery Policy
DP World Code of Ethics
Human Rights Policy
Human Rights Statement
Modern Slavery & Human Trafficking Policy
Vendor Code of Conduct
Together, these policies form an integrated framework that reinforces our commitment to integrity, transparency, accountability, and respect for human rights throughout our operations and supply chain. All stakeholders are expected to familiarise themselves with these documents and apply them where relevant in the course of their work.
Definitions and Terms
In this Policy the following definitions apply, unless the context requires otherwise:
| Audit and Risk Committee | a committee comprising non-executive Directors that ensures the Committee integrity of the financial reporting and audit process and oversees the maintenance of sound internal control and risk management systems. |
| Conflicts of Interest | may take many forms, actual or perceived, but generally arises when a person could use his or her position to a) influence the Group's business decisions in ways to give improper advantage or financial benefit to oneself and/to others, or b) to obtain for oneself and/or others a financial benefit beyond the compensation he or she is authorized to receive for performing his or her responsibilities. |
| Fraud | means an intentional dishonest act or omission carried out with the purpose of deceiving, inducing a course of action or the making of false statements, orally or in writing, with the objective of obtaining money or other benefits from the Group, or of evading liability to the Group. Fraud is not restricted to monetary or material benefits. This definition includes monetary gain and any benefit that could be gained from the Group. |
| Group | refers to DP World, its subsidiaries and any company or entities managed or operated by them. |
| Group Internal Audit | refers to an independent body established by The DP World Limited Board of Directors with oversight by the DP World Limited Board Audit and Risk Committee. |
| Investigation | a process designed to gather and analyse information, to determine whether a fraud incident report is substantiated, or if any dishonest or unethical acts have occurred and if so, the party or parties responsible. |
| Management | this includes all Executive Management of the Group at every level and location, this includes but is not limited to, SVPs, VPs and Heads of Departments or Divisions. |
| Malicious | an unfounded and untrue report made that is characterized by malice, hatred, and disregard or to be deliberately harmful or spiteful. |
| Recklessly | where an act has taken place in such a manner that the party carrying out the act is indifferent to or disregardful of the consequences. Some form of loss is usually associated with acts of recklessness. Recklessly also means being neglectful, careless, thoughtless and unconcerned. |
| Stakeholder | in this policy context means any employee, (direct and indirect), partner, customer, any person or entity involved in the Group's supply chain, as well as members of the public who wish to express any sort of concern about the Group's business integrity. |
| Whistleblower | a person, who is, or represents, a stakeholder and who raises a genuine concern in 'good faith' and discloses information of suspected wrongdoing. |
| Whistleblowing | the disclosure of information which relates to suspected wrongdoing, and not information disclosed maliciously, recklessly or for personal gain. This may include: o Criminal activity o Miscarriages of justice o Danger to health and safety o Damage to the environment o Failure to comply with any legal or professional obligation or regulatory requirements o Bribery o Financial fraud or mismanagement o Negligence o Breach of DP World internal policies and procedures including breaches concerning Human Rights and any form of trafficking. o Conduct likely to damage DP World’s reputation o Unauthorised disclosure of confidential information o The deliberate concealment of any of the above matters. |
History
| Version Number | Review Date | Summary of Changes |
| 5.0 | February 2022 | Updates to reflect the change in whistleblowinghotline service provider, and other changes in reporting. |
This Policy has been developed by Fraud Risk Services and is subject to annual review.
Approved by: Group Chairman and CEO Fraud Risk Services
Revision Number: 5.0 Revision Date: February 2022
ALL QUERIES IN RELATION TO THIS POLICY SHOULD BE DIRECTED TO
THE HEAD OF FRAUD RISK SERVICES AT
FRS@DPWORLD.COM