Whistleblowing and Fraud Reporting
Confidential whistleblowing channels for reporting fraud, misconduct and policy breaches — plus anti-retaliation protection.
Group Policy & Procedure | Document No. | P-POL-018 |
Group Supply Chain | Ver. No. | Rev Date | 0.4 | 08 APR 2026 |
Title: Whistleblowing & Fraud Reporting | Effective Date | 08 April 2026 |
BUKHATIR GROUP
Strength through Diversity
Group Policy and Procedure
Group Supply Chain (GSC)
Whistleblowing & Fraud Reporting
Confidential Channels & Non-Retaliation
Document No: P-POL-018
Copyright © 2026 Bukhatir Group
Revision Control
This document is issued under the authority of Bukhatir Group and applies when carrying out the activities described. Revisions may be issued as necessary under the authority of the Group Head of Procurement. Revision history is recorded below with every revised policy.
Revision History
Ver. No. | Effective Date | Description |
|---|---|---|
02 | September 2016 | Original Procurement Policy |
0.3 | March 2026 | Procurement Policy – Whistleblowing & Fraud Reporting |
0.4 | 08 April 2026 | Redesign, content modernization & flowcharts – Whistleblowing & Fraud Reporting |
Revision Sign-Off
Approving Committee | Name | Signature |
|---|---|---|
Endorsed by — Group Head of Supply Chain | Mohamad Koussa | |
Reviewed by — BIIL CEO | Mr. Ayman Ismail | |
Reviewed by — Group Chief Financial Officer | Mohamad Adnaan Sait | |
Approved by — Group Vice Chairman & Group CEO | Mr. Salah Bukhatir |
Distribution List
# | Departments |
|---|---|
1 | Business Unit Procurement Departments |
2 | Group Supply Chain (GSC) |
3 | Finance, Legal, Compliance, Internal Audit |
4 | Business Unit Management |
1. Purpose
This policy establishes secure and confidential channels through which employees, suppliers and third parties may report suspected fraud, bribery, corruption, policy breaches or unethical behaviour in the procurement function, without fear of retaliation.
2. Scope
Applies to all Group staff, contractors, consultants and suppliers. Reports may concern any procurement-related activity across the Group.
3. Reporting Channels
- Dedicated email: whistleblow@bukhatirgroup.com (monitored by Compliance and Internal Audit).
- Confidential hotline: operated independently, available 24/7.
- Secure web portal with anonymous submission option.
- Direct report to the Group Head of Compliance or the Audit Committee Chair.
4. Scope of Reportable Matters
- Fraud, theft, embezzlement, false invoicing.
- Bribery, kickbacks, secret commissions.
- Collusion, bid-rigging, cartel behaviour.
- Conflicts of interest not declared.
- Breach of sanctions, anti-bribery or labour law.
- Data protection and cyber-security breaches.
5. Confidentiality & Non-Retaliation
PROTECTED DISCLOSURE Bukhatir Group guarantees confidentiality for good-faith reporters. Retaliation, harassment or disciplinary action against a reporter is itself a serious breach and is treated as grounds for dismissal. |
6. Investigation Process
- Intake and logging by Compliance within 24 hours.
- Triage and risk assessment.
- Independent investigation by Internal Audit or external investigator for material matters.
- Findings reported to the Audit Committee; remedial actions tracked to closure.
- Feedback to the reporter (where contact details provided).
7. Reference Form
Form F-WB-01 — Whistleblowing Report Form (anonymous option available).
8. Definitions & Acronyms
Acronym / Term | Definition |
|---|---|
BU | Business Unit |
COI | Conflict of Interest |
GSC | Group Supply Chain |
HR | Human Resources |
UAE | United Arab Emirates |