Foundation in support of the World Health Organization (“WHOF”)

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Whistleblowing Policy

November  2022

Purpose of the whistleblowing policy

The Foundation in support of WHO (“WHOF”) is a Swiss independent Foundation, whose purpose is to support the global health ecosystem and promote health as a global public good.

The WHOF is committed to the highest possible standards of integrity, transparency and accountability in all its affairs. For this purpose, the WHOF is developing a comprehensive set of policies to align engagements, internal or external, with our mission and protecting our independence and integrity.

The whistleblowing policy (the “Policy”) is an expression of the WHOF’s zero-tolerance of fraud, corruption, sexual harrassment and other violations of applicable laws or policies related to WHOF activities and beneficiaries and is intended to provide clear avenues for exposing (potential or alleged) infringements and violations. As a conduit of funds designated to address global health needs, the WHOF has an overriding duty to manage those funds responsibly, including but not limited to, proactively protecting those funds from any abuse or misdirection so that they can reach their intended destinations for their intended purposes.

The Policy aims to empower anyone covered by its provisions to report serious suspicions of wrongdoing or misconduct in good faith and without fear of retaliation so that the WHOF can effectively:

➔ Protect employees, consultants, board members and other parties involved with WHOF and the WHOF from behavior that does not adhere to the WHOF’s core values; and
➔ Protect the WHOF purpose, resources, and interests and beneficiaries by detecting and mitigating risks as early as possible, and by continuously improving its internal control mechanisms.

Scope of the Policy

The Policy can be applied by (i) whistleblowers such as the WHOF’s former or current employees, consultants and board members, as well as (ii) third parties involved with the WHOF work (including but not limited to, donors, service providers, fiduciary partners, ambassadors or implementing partners).

The Policy shall be used to alert about serious suspicions of wrongdoing or misconduct by WHOF’s employees, consultants or board members according to the list below affecting people directly related to the WHOF’s activities or its environment.

Wrongdoing and misconduct encompass any of the circumstances listed below:

➔ Corruption and financial irregularities, including but not limited to bribes, embezzlement, misappropriation, money laundering and fraud;
➔ Potential or actual conflict of interests, including but not limited to irregularities in tender processes and favoritism in the award of a contract to a third party;
➔ Violation of human rights (1), including but not limited to, violation in relation to the WHOF’s funded programs;
➔ Sexual or psychological harrassment in any form, or discrimination based on ethnicity, nationality, religion, gender, sexual orientation, or other factors, made by WHOF employees, consultants or board members or in relation to any activities of the WHOF;
➔ Communication of false information (e.g. false financial reporting) and inappropriate disclosure or reporting of such false information;
➔ Waste or misuse of the WHOF resources and/or assets;
➔ Non-compliance or violation of the WHOF set of policies, including but not limited to, the WHOF Gift Acceptance Policy and the WHOF Child Protection Policy;
➔ Breach of internal policies, processes or guidelines, including but not limited to, if applicable, the WHOF’s Code of Conduct and Ethics that the whistleblower wishes to report anonymously;
➔ Abuse of power or authority;
➔ Privacy violations (e.g. improper use of personal data).

For issues relating to dissatisfaction in the workplace or related matters, the WHOF employees or consultants are encouraged to proceed according to the WHOF Code of Conduct and Ethics, unless anonymity is preferred.

Process to report misconduct or wrongdoing

Reports can be made anonymously or confidentially to one of the Ethics Officers of the WHOF (2) (“Ethics Officers”) directly or through the online reporting channel provided: https://report.whistleb.com/en/whofoundation.
Ethics Officers are trained permanent employees of the WHOF, and are not members of the Executive Management Team.

The reporting channel is administered through an external service provider, through which all messages are encrypted, metadata and IP addresses are deleted.

Through the external reporting channel the whistleblower can place a report anonymously or not, according to his/her preference. The WHOF is committed to safeguard whistleblowers and provides the opportunity to treat all whistleblowing reports as either confidential (3) or anonymous. The choice between a confidential or an anonymous report is the sole decision of the whistleblower. If further investigation is required after an anonymous report, all exchanges will take place through the external platform to ensure that anonymity can be preserved in the dialogue between the Ethics Officer and the Whistleblower.

A whistleblower does not need to have firm evidence for expressing a suspicion. However, deliberate reporting of false or malicious information can result in consequences as outlined below.

The Ethics Officers report yearly to the Finance and Audit Committee of the Board (the “FAC”).

Investigation process

Upon receipt of a report by the Ethics Officers, the whistleblower will receive communication to acknowledge receipt of the complaint within seven working days from submitting the report.

All reports are treated seriously and in accordance with the Policy and below principles:

➔ No Ethics Officers, or anyone taking part in the investigation process, will attempt to identify the whistleblower;
➔ Ethics Officers can, when needed, submit follow-up questions via the online reporting channel that allows anonymous communication;
➔ Whistleblowing reports are handled confidentially by the parties involved;
➔ The Ethic Officer may draw internal or external expertise in the investigation (4). These individuals may have access to relevant data and are also bound to confidentiality;
➔ A report will not be investigated by anyone who may be perceived to be involved with or connected to the misconduct or wrongdoing.

Ethics Officers will not investigate a reported misconduct or wrongdoing, if:

➔ the alleged wrongdoing does not fall within the scope of the Policy;
➔ there is insufficient information to allow for further investigation; or
➔ the subject of the report has already been addressed in a previous report.

The Ethics Officers will conduct a preliminary investigation of the allegation and any evidence made available, resulting in a determination of the most appropriate action. If appropriate, the Ethics Officer can seek consultation and support, for the preliminary investigation, from the Legal and/or People & Culture team, or any additional resource as considered essential, ensuring that the confidentiality is maintained and that such support will not result in a conflict of interest. In addition, where appropriate, while maintaining confidentiality and ensuring there is no conflict of interests, the matter may be communicated to managers of the WHOF for action.

If a potential or existing conflict of interest is raised during this preliminary phase, in particular in relation to WHOF’s managers, the Ethic Officers may communicate and decide the course of action in consultation with the FAC or one of its members, while ensuring confidentiality or anonymity of the whistleblower.

At the conclusion of the WHOF internal investigation, if appropriate, Ethic Officers may refer the matter for action (i) to the management of the WHOF, (ii) to the FAC and/or (iii) to external authorities, i.e. prosecutor, authorities, external auditors, external counsel of the WHOF, internal investigative functions of beneficiary or implementing agencies or any other relevant person. If appropriate for these steps, the Ethic Officers can seek consultation and support from the Legal team ensuring that the confidentiality is maintained and that such support will not result in a conflict of interest.

The Ethic Officers should inform the whistleblower about the result of the internal preliminary investigation within a three month deadline after sending the acknowledgement of receipt of the complaint.

Subject to considerations of the privacy of those against whom allegations have been made, and any other issues of confidentiality or legal nature, a whistleblower will be kept informed of the outcomes of the investigation into the allegations.

Whistleblower protection against retaliation

The WHOF will not tolerate any retaliation (i.e. any act of discrimination, reprisal, harassment or vengeance), direct or indirect, which is recommended, threatened or taken against a whistleblower or its relatives or associates.

Where an individual makes a report under this policy in good faith, no retaliation against the individual will be tolerated should the disclosure turn out to be unsubstantiated.

The WHOF is committed to preventing those who benefit from wrongdoing or misconduct from attempting to retaliate against or victimize a whistleblower for loss, or potential loss, of that ill-gotten benefit.

In case of retaliation, the whistleblower should report the facts as soon as possible in order to receive protection through the implementation of appropriate measures (e.g. a temporary reassignment with the consent of the whistleblower subject of retaliation).
Retaliators will be subject to administrative and/or disciplinary action.
Making a report that is known to be false or intentionally misleading constitutes misconduct and may result in administrative, disciplinary or other appropriate action against the whistleblower. Any person who makes such a report will not be protected by the Policy.

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1. As per the United Nation definition (https://www.un.org/en/global-issues/human-rights), Human rights are rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status. Human rights include the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression, the right to work and education, and many more. The rights mentioned in the Universal Declaration of Human Rights (UDHR) are to be strictly complied with by the WHOF.
2. The WHOF will have at all times at least two Ethics officers from different departments, in order to be able to receive any type of complaint.
3. Confidentiality clauses or equivalent in contracts of employment, consultant or any other contract do not preclude a duty to disclose wrongdoing/misconduct.
4. For example, in case of criminal offense the legal team can be involved by Ethics Officers to support if no conflict of interest is identified and full confidentiality.