Whistleblowing Policy

"bee Charity" Verein (“BeeCharity”, “we”, “us”, “our”) is a Swiss association (Verein) with its seat in Dübendorf, Canton of Zurich, registered in the Commercial Register Office of the Canton of Zurich under UID CHE-457.076.818. We are committed to conducting our work with honesty, integrity and accountability, and we depend on the trust of donors, beneficiaries, volunteers, partners and the public. Sometimes the people connected with an organisation are the first to become aware that something is seriously wrong, and we want them to feel able to speak up.

The purpose of this Whistleblowing Policy is to provide a clear, safe and confidential way for people to raise genuine concerns about serious wrongdoing connected with BeeCharity — such as fraud, corruption, a danger to the safety of children or vulnerable people, or other serious misconduct or illegality — without fear of being penalised for doing so. It reflects our belief that raising a genuine concern is a responsible and valuable act that helps us put things right, protect people, and safeguard the reputation and resources entrusted to us.

This policy explains what kinds of concern it covers, how to raise them, how we protect the confidentiality of those who come forward, how we investigate, and how we protect people against retaliation. It is deliberately designed to work for a small organisation with a two-member board, so that a concern can always reach someone other than the person it is about. It was formally adopted by the board and is published in the spirit of transparency; it describes the standards we hold ourselves to.

This policy covers “protected disclosures” — that is, concerns raised in good faith about serious wrongdoing connected with BeeCharity. It is intended for matters of genuine public or organisational concern, rather than personal grievances, and it applies to concerns about, for example:

You do not need to be certain that wrongdoing has occurred, and you do not need to have proof — a genuine, reasonably held concern is enough. What matters is that the concern is raised honestly and in good faith. You will be protected under this policy even if, after investigation, it turns out that you were mistaken, provided you acted honestly. Knowingly making a false or malicious allegation, on the other hand, is itself a serious matter and may be dealt with under our other policies.

This policy is for serious concerns about wrongdoing. Personal complaints about how you have been treated — for example an individual dispute about your own volunteering — are normally better dealt with under our Complaints Policy or Volunteer Policy, and safeguarding concerns are handled through our Safeguarding and Child Protection Policy; but if you are unsure which route is right, raise the matter anyway and we will help direct it appropriately.

• Fraud, theft, bribery, corruption or other financial impropriety, or the misuse of donations and charitable funds.
• Danger to the health, safety or welfare of any person, and in particular any safeguarding concern involving a child or vulnerable person.
• A breach of a legal or regulatory obligation, or conduct that is otherwise unlawful.
• Serious breaches of our own policies, or serious misconduct by anyone acting for BeeCharity.
• Damage to the environment, or conduct inconsistent with our environmental mission.
• The deliberate concealment of any of the above, or an attempt to cover such matters up.

We want it to be as easy and safe as possible to raise a concern, and there is more than one route so that you can always find one you are comfortable with. In many cases the quickest way to have a concern addressed is to raise it directly with a member of the board; but we recognise that this is not always appropriate, particularly where the concern involves a board member, and so alternative routes are always available.

You can raise a concern under this policy in writing or verbally. You may contact the board at beecharity1@gmail.com, or write to us by post at the address in the Contact chapter below, marking your correspondence for the attention of the board. Because BeeCharity currently has a two-member board and operates under joint signing authority, we have made sure that a concern never has to be raised only with the person it is about: where your concern involves one board member, you can raise it with the other board member, and where it concerns both, or you do not feel able to approach either, you can raise it through the wider membership of the association or ask a trusted third party to do so on your behalf.

When you raise a concern, it helps us if you can explain what you are worried about, why, and any relevant facts, dates or documents — but please do not delay raising a concern because you feel you lack detail, and please do not try to investigate the matter yourself. You may raise a concern anonymously, and we will take anonymous concerns seriously and act on them so far as the information allows; however, we encourage you to identify yourself where you can, because it is usually easier to investigate a concern, and to protect and update the person who raised it, when we are able to go back to them for more information.

We treat concerns raised under this policy as confidentially as we possibly can, and we will not disclose the identity of a person who has raised a concern in good faith without their consent, unless we are required to do so by law or it becomes genuinely unavoidable in order to investigate the matter properly. Where disclosure of your identity may become necessary — for example because the investigation cannot proceed fairly without it — we will discuss this with you first wherever we can, and consider how best to protect you.

We ask everyone involved in raising, receiving or investigating a concern to respect its confidentiality, and to share information about it only with those who genuinely need to know in order to deal with it. This protects the person who came forward, protects anyone who is the subject of an allegation that has not yet been established, and protects the integrity of the investigation itself. Any personal data processed in connection with a whistleblowing concern is handled in accordance with our Privacy and Data Retention policies, and kept secure with access strictly limited.

If you raise a concern anonymously, we will of course have no identity to protect, but we will still handle the matter itself confidentially. Whether or not you identify yourself, we ask that you also keep the fact and content of your concern confidential while it is being dealt with, so that the investigation is not prejudiced and so that no one is unfairly exposed before the facts are established.

Every concern raised under this policy is taken seriously and assessed promptly. When we receive a concern we will, wherever we can, acknowledge it, clarify what is being alleged, and decide how it should be handled — which may mean investigating it under this policy, referring it to another policy (such as Safeguarding, Anti-Fraud or Complaints), or, where appropriate, referring it directly to an external authority such as the police, a regulator, or child-protection services.

Investigations are carried out fairly, objectively and confidentially, and proportionately to the seriousness and complexity of the concern. We take prompt steps to preserve relevant evidence and, where necessary, to prevent further harm or loss — for example by suspending a payment, restricting access to an account or system, or temporarily standing a person back from a role while the matter is examined. Any such step is a neutral, precautionary measure and is not a finding that anyone has done wrong. A concern will not be investigated by any person who is the subject of it or who has a conflict of interest in it; given our small board, where necessary we will involve the wider membership or seek independent or professional support to ensure the investigation is impartial.

Anyone who is the subject of an allegation will be treated fairly, told what is alleged against them (at an appropriate stage and so far as is consistent with a proper investigation), and given a genuine opportunity to respond before any conclusion is reached. So far as it is appropriate and lawful, we will keep the person who raised the concern informed about how it is being handled and its broad outcome, while respecting the confidentiality and rights of others. Where an investigation reveals that we need to change how we work, we act on that as part of putting things right.

No one who raises a genuine concern in good faith under this policy will suffer any detriment, disadvantage or retaliation as a result of having done so, and this is a firm commitment on which the whole policy depends. Retaliation might take the form of, for example, being excluded from activities, being removed from or denied a role, being treated less favourably, being harassed or victimised, or being subjected to any other form of reprisal — and all such conduct is strictly prohibited, whether directed at the person who raised the concern or at anyone who assisted or supported them.

This protection applies even if the concern turns out, after investigation, to be mistaken or unproven, provided the person raised it honestly and reasonably. It is the good faith of the person raising the concern that matters, not whether they were ultimately right. We regard the protection of those who speak up as essential: if people fear reprisal, serious wrongdoing goes unreported, and the very harms this policy exists to prevent are allowed to continue.

Anyone who subjects a whistleblower to retaliation will be regarded as having committed a serious breach of our standards, which may result in their involvement with BeeCharity being ended and, where appropriate, in referral to external authorities. If you raise a concern and then believe you are being subjected to retaliation, please report this immediately through the routes in this policy, and we will treat it as a serious matter in its own right. This protection does not, however, extend to someone who knowingly makes a false or malicious allegation, which remains a disciplinary matter.

The board has overall responsibility for this policy and for ensuring that concerns raised under it are handled properly, fairly and without reprisal. Because BeeCharity is governed by a two-member board acting under joint signing authority, we have given particular thought to how whistleblowing is governed so that no concern is ever left to be judged solely by the person it concerns.

Where a concern relates to one board member, the other board member takes responsibility for ensuring it is handled, involving the wider membership or independent support as needed. Where a concern relates to both board members, or to the board as a whole, it can be escalated to the general meeting of the association’s members, and where appropriate to an external authority such as a regulator or the police, so that it does not depend on the very people it concerns. Decisions that bind the association in response to a whistleblowing matter remain subject to our joint signing authority and to the safeguards in our Conflicts of Interest Policy.

The board maintains proportionate oversight of concerns raised under this policy — including keeping a confidential record of concerns received, how they were handled and their outcomes — so that it can satisfy itself that the policy is working, identify any patterns or recurring problems, and demonstrate that concerns are taken seriously. This oversight is exercised consistently with the confidentiality protections described above, and this policy operates alongside our Safeguarding, Anti-Fraud, Complaints, Conflicts of Interest, Privacy and Data Retention policies.

When an investigation is complete, we decide on the appropriate outcome in light of the findings, always with the aim of putting right what has gone wrong, protecting people and funds, and preventing a recurrence. The action we take depends on the nature and seriousness of the matter, and may combine several of the steps below.

Where wrongdoing is established, outcomes may include recovering misused funds; correcting failures in our systems, controls or practices; ending the involvement of a volunteer, board member, contractor or partner responsible for serious misconduct; and reporting the matter to the relevant external authorities — such as the police, a regulator, or child-protection services — where the law requires it or where it is otherwise the right thing to do. Safeguarding matters are dealt with under our Safeguarding and Child Protection Policy, and financial wrongdoing under our Anti-Fraud, Bribery and Corruption Policy, so that the specialist steps in those policies are applied.

Where a concern is not upheld, we will say so, and the person who raised it in good faith will remain fully protected under this policy. In every case we seek to learn from what has happened: even a concern that is not substantiated can reveal a weakness we should address. So far as confidentiality and the rights of others allow, we will let the person who raised the concern know that the matter has been dealt with and, in general terms, its outcome, so that they can see their concern was taken seriously.

This policy was formally adopted by the board and is reviewed at least annually, or sooner if there is a relevant change in Swiss or applicable law, in recognised good practice on whistleblowing, or in the nature and scale of our activities. As BeeCharity grows — for example if the board expands or if we take on employees — we will develop this policy so that it continues to provide safe and effective routes for raising concerns.

Any material change to this policy is approved under our joint signing authority, with two authorised representatives acting together. The version and status shown at the top of this page reflect its current standing as a policy formally adopted by the board, and we will update the version history when it is adopted or amended. We welcome suggestions on how to make it easier and safer for people to raise concerns.

If you have a serious concern about wrongdoing connected with BeeCharity, or a question about this policy, please contact us using one of the routes below. If a child or vulnerable person is in immediate danger, contact the local emergency services first, and then notify us.

Whistleblowing concerns (the board): beecharity1@gmail.com

Safeguarding concerns: beecharity1@gmail.com

General enquiries: beecharity1@gmail.com

Postal address: "bee Charity" Verein, c/o Jasmin Semra Gabrielli, Bahnhofstrasse 33, 8600 Dübendorf, Switzerland (please mark correspondence “Confidential — For the attention of the Board”)