Whistleblower Policy
ITSA encourages reporting of reasonably suspected wrongdoing and prohibits retaliation for a good-faith report, reasonable participation in an investigation or refusal to take part in unlawful conduct. This policy provides ITSA's own reporting and handling commitments. It does not depend on a claim that a statutory whistleblower office or every provision of the Whistleblower Protection Act 10 of 2017 is operational.
1 What can be reported
Report suspected bribery, fraud, theft, money laundering, serious safety or environmental harm, unlawful discrimination or harassment, misuse of personal information, deliberate security failures, false records, procurement misconduct, retaliation or concealment of wrongdoing. Proof is not required, but describe the basis for the concern honestly. A report that is not substantiated is not automatically malicious.
Ordinary service queries and individual employment grievances may be handled through their normal routes, unless they involve wrongdoing, retaliation or a conflict that makes that route unsuitable. ITSA must route a matter fairly rather than reject it merely because the reporter chose the wrong label.
2 Internal reporting routes
You may report orally to a trusted supervisor or directly to the Managing Member, in writing to [email protected] with the subject Confidential disclosure, or by a sealed letter marked Private and confidential for the Managing Member at ITSA's published office address. You may ask for a private meeting and a secure method for providing evidence. Ordinary email is not a guaranteed anonymous or end-to-end confidential channel.
If the Managing Member or intended recipient is implicated, do not send the report to that person. Approach an unconflicted member if one is available, or a competent external authority directly. Where no suitable internal recipient exists, external reporting remains available; this policy does not invent an independent hotline or external investigator already appointed by ITSA. An investigator must be free from material conflict and may be external where needed.
3 External reporting and emergencies
You do not need ITSA's permission to make a lawful report to a regulator, the Namibian Police, the Anti-Corruption Commission, the Labour Commissioner or another competent authority, or to obtain independent legal advice. For corruption, the ACC's published reporting information is available through the Anti-Corruption Commission. For suspected laundering use the Financial Intelligence Centre. Check the authority's current reporting procedure and disclose only information lawfully appropriate to that report.
For immediate danger seek emergency assistance directly. An internal report does not stop a legal deadline or guarantee that public disclosure to the media has statutory protection. Do not destroy evidence, unlawfully access systems or unnecessarily distribute personal information to make a report. ITSA's internal approval procedures must not obstruct an individual's statutory reporting duty.
4 Anonymous reports and confidentiality
Anonymous reports will be considered on their available facts. A sealed letter without a name can be used, but lack of a contact route may limit follow-up and feedback. ITSA must not promise that an email, office visit or computer record cannot reveal identity. Where possible, agree a safe means of communicating without unnecessary identifying details.
Share identity and case information only with people who need it for assessment, protection, investigation, fair response or a legal duty. Confidentiality is subject to lawful disclosure and fair-process requirements. Explain foreseeable limits where practicable and consult the reporter before voluntary identity disclosure that may create risk. Do not promise absolute secrecy or legal immunity.
5 Receipt assessment and investigation
The recipient must promptly protect the record, check conflicts, assess urgency and consider interim protection. The handling target is acknowledgement within five business days where contact is possible, followed by an initial assessment within ten business days. An urgent safety, criminal or security risk requires earlier action. These are ITSA targets and do not extend any statutory deadline.
An unconflicted responsible person must determine scope, investigator, evidence preservation, access restrictions and external referral duties. Investigations must be proportionate, impartial and fair to all affected people. Give a person facing an adverse finding an appropriate opportunity to respond without disclosing unnecessary identities or compromising a lawful investigation. Maintain a record of decisions, evidence and reasons.
6 Protection from retaliation
Do not dismiss, demote, threaten, harass, disadvantage, blacklist, reduce work opportunities or disclose identity to punish a protected report or participation. A supervisor must assess risks and implement reasonable protective measures without treating the reporter as the problem. Examples may include alternative supervision, restricted case access or agreed adjustments, with regard to the reporter's wishes and others' rights.
Report retaliation through any safe route in this policy, bypassing the person involved. Investigate it as a separate concern and take proportionate action. Protection does not exempt unrelated misconduct from fair action, but ITSA must show that any action is based on legitimate reasons independent of the report. Knowingly fabricated allegations or deliberate evidence falsification may be misconduct after fair process; an honest mistake is not.
7 Feedback records and remedies
Provide appropriate progress information at least every thirty calendar days during an open matter where contact is possible, and explain significant delay. Give a closure summary as far as privacy, safety and law allow; reporters are not entitled to another person's confidential employment file. Findings may lead to corrective measures, recovery of losses, fair disciplinary action or referral to authorities. ITSA cannot promise a particular prosecution or outcome.
Store case records separately with restricted access, a proportionate retention period and any necessary legal hold. The unconflicted responsible member must review themes and unresolved retaliation risks without circulating identifying details unnecessarily. Review this policy annually and verify the commencement and operation of relevant whistleblower legislation when updating procedures. ITSA's non-retaliation commitment applies independently of that verification.