Fulfillant Whistleblower Policy

Last Updated: [2018-01-01]

1. Policy Purpose and Overview

Fulfillant is committed to conducting business with integrity, transparency, and in compliance with all applicable laws and regulations. This Whistleblower Policy aims to:

  • Encourage employees, contractors, suppliers, and other stakeholders to report suspected wrongdoing, misconduct, or unethical behavior in good faith without fear of retaliation.
  • Provide clear and confidential channels for reporting concerns.
  • Ensure that all reports are investigated promptly, fairly, and thoroughly.

2. Scope

This policy applies to all employees (full-time, part-time, temporary), directors, officers, contractors, suppliers, agents, and any other parties engaged in business with Fulfillant.

3. Definitions

  • Whistleblower: An individual who makes a qualifying disclosure of reportable conduct under this policy.
  • Reportable Conduct: Actions or omissions that the Whistleblower has reasonable grounds to suspect involve:
    • Illegal activities (e.g., fraud, corruption, bribery, theft).
    • Violations of national or international law.
    • Breaches of Fulfillant’s internal codes of conduct or policies (e.g., Anti-Bribery and Corruption Policy).
    • Unethical behavior or serious misconduct.
    • Conduct that endangers health and safety or causes significant environmental damage.
    • Financial malpractice, mismanagement, or falsification of financial records.
    • Concealment of any of the above.
  • Good Faith Report: A report made honestly and with the belief that the information is true, even if it later proves to be incorrect. Maliciously false or vexatious reports are not considered good faith.

4. Reporting Channels

To ensure accessibility and confidentiality, concerns can be raised through the following dedicated channels:

  • Primary Channel:Email to the Ethics Committee
    • Address: ethics@fulfilldog.com
    • This mailbox is managed by designated, trusted personnel.
  • Alternative Channel:Written Report
    • Mailed to: The Ethics Committee, Fulfillant, 2nd Floor, Building 7, Baicai Technology Park, Niushan Woling Industrial Zone, Huijing Road, Dongcheng Street, Dongguan City, Guangdong Province, China.
    • The envelope should be marked “STRICTLY CONFIDENTIAL.”

5. Confidentiality and Anonymity

  • Confidentiality: Fulfillant will treat the identity of the Whistleblower and the content of the report with the strictest confidence to the fullest extent possible, consistent with the need to conduct a competent and thorough investigation.
  • Anonymity: Reports can be made anonymously. However, providing contact information is encouraged as it may assist in a more effective investigation. Anonymous reports should contain sufficient detail to allow for a proper investigation.

6. Non-Retaliation

Fulfillant strictly prohibits any form of retaliation, harassment, or victimization against an individual who has made a good faith report under this policy. Retaliation is a serious violation of this policy and will result in disciplinary action, up to and including termination of employment or contract.

Any individual who believes they are experiencing retaliation should report it immediately through the same channels outlined in Section 4.

7. Investigation Process

  • Acknowledgment: Reports will be acknowledged within 5 business days if contact details are provided.
  • Investigation: All reports will be reviewed promptly by the designated Ethics Committee. The investigation will be objective, impartial, and conducted by individuals with the appropriate expertise and authority.
  • Cooperation: All employees and relevant parties are required to cooperate fully with investigations conducted under this policy.
  • Outcome: Upon conclusion of the investigation, the Whistleblower will be informed of the outcome to the extent appropriate and permitted by law.

8. Good Faith and Protection Against Malicious Reports

This policy is designed to protect individuals who make disclosures in good faith. It is not a shield for individuals who make knowingly false or malicious allegations. Any individual found to have made a report in bad faith may be subject to disciplinary action.

9. Policy Administration and Review

This policy is administered by the Fulfillant Ethics Committee. The policy will be reviewed annually and may be amended to reflect legal developments and best practices.

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