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Whistleblower Policy

Effective Date: July 16, 2025

1. Purpose

insureOnGo is committed to the highest standards of ethical, moral and legal business conduct. This Whistleblower Policy (“Policy”) encourages employees, contractors, customers and third parties to report any suspected misconduct—without fear of retaliation—in line with best practices from KPMG, Deloitte, PwC and EY.

2. Scope

This Policy applies to all employees (full‑time, part‑time, temporary), consultants, contractors, interns, vendors and any third‑party service providers of insureOnGo worldwide.

3. Definitions

• “Whistleblower” – Any individual who reports a good‑faith concern about potential violations of law, policy, or ethical standards.
• “Misconduct” – Fraud, corruption, bribery, financial irregularities, data breaches, harassment, discrimination, or any other unethical or illegal conduct.
• “Retaliation” – Any adverse action taken against a Whistleblower for reporting concerns, including dismissal, demotion, harassment, or any form of discrimination.

4. Reporting Channels

You may raise concerns through any of the following confidential channels:

• Whistleblower Hotline: +1 (234) 567‑890 (24/7 automated service)
• Email: whistleblower@insureongo.com
• Postal Mail:
  Whistleblower Officer
  insureOnGo
  1234 Insurance Blvd,
  Lagos, Nigeria

5. Anonymous Reporting

Whistleblowers may choose to remain anonymous. However, providing contact details may assist in follow‑up inquiries and investigations.

6. Non‑Retaliation

insureOnGo prohibits any form of retaliation against individuals who report concerns in good faith. Any employee found to have retaliated will face disciplinary action, up to and including termination.

7. Investigation Process

1. Intake: All reports are logged by the Whistleblower Officer within 2 business days.
2. Preliminary Review: The Officer assesses credibility and determines if a full investigation is warranted.
3. Investigation: A designated team (legal, compliance, HR, or external counsel) conducts interviews, gathers evidence, and documents findings.
4. Findings & Actions: Final findings are reviewed by senior management. Corrective and disciplinary actions are implemented as needed.
5. Feedback: Whenever possible, the Whistleblower is informed of the outcome without breaching confidentiality of others involved.

8. Confidentiality

All reports and investigations will be treated confidentially to the fullest extent possible. Information will only be shared on a need‑to‑know basis.

9. Responsibilities

• Employees & Third Parties: Promptly report any suspected misconduct.
• Managers & Supervisors: Encourage open communication and ensure no retaliation occurs.
• Whistleblower Officer: Receive, log, investigate, and track all reports; maintain confidentiality.
• Senior Management: Review investigation outcomes and enforce corrective actions.

10. Record Keeping

All records related to whistleblower reports and investigations will be retained for a minimum of 7 years, in accordance with statutory requirements.

11. Policy Review

This Policy will be reviewed annually by the Compliance Committee—or sooner if required by changes in law or organizational structure—to ensure ongoing effectiveness.

insureOnGo is committed to integrity, transparency, and accountability.