Whistleblower Policy

Our commitment to ethical conduct, confidential reporting, accountability and protection from retaliation for employees, contractors, customers, vendors and third parties.

Effective: 16 July 2025  |  Last reviewed: May 2026  |  Version: 1.0

1. Purpose

InsureOnGo.Com Partnering Insurtech Limited (“InsureOnGo”, “we”, “us”) is committed to the highest standards of ethical, moral and legal business conduct. This Whistleblower Policy provides a safe, confidential and responsible channel for reporting suspected misconduct in good faith.

The purpose of this Policy is to encourage employees, contractors, customers, vendors, service providers, business partners and other third parties to speak up where they reasonably suspect wrongdoing, without fear of intimidation, victimisation or retaliation.

2. Scope

This Policy applies to all directors, employees, officers, interns, consultants, contractors, vendors, service providers, business partners and any third party dealing with InsureOnGo.

It covers concerns relating to suspected breaches of law, regulation, internal policy, ethical standards, corporate governance obligations, data protection requirements, financial controls or any conduct capable of damaging our customers, partners, employees, regulators, shareholders or reputation.

3. Definitions

  • “Whistleblower” — any person who reports a good-faith concern about suspected misconduct, unethical behaviour, breach of policy or violation of law.
  • “Misconduct” — fraud, bribery, corruption, theft, financial irregularity, data breach, harassment, discrimination, abuse of authority, conflict of interest, regulatory breach, concealment of wrongdoing or any other illegal or unethical conduct.
  • “Good faith report” — a report made honestly and on reasonable grounds, even if the concern is later not substantiated.
  • “Retaliation” — any adverse action taken against a whistleblower because of a good-faith report, including dismissal, demotion, intimidation, harassment, discrimination, threats, victimisation or unfair treatment.

4. Reporting channels

Concerns may be reported through any of the following confidential channels:

Reports should, where possible, include the nature of the concern, date, location, persons involved, supporting documents, witnesses and any other information that may assist a fair review or investigation.

5. Anonymous reporting

Whistleblowers may choose to remain anonymous. However, providing contact details may assist us with follow-up questions, evidence gathering and communication of permitted investigation updates.

Anonymous reports will be assessed on the information available. Where the report lacks sufficient detail, investigation may be limited unless additional information can be obtained.

6. Non-retaliation

InsureOnGo strictly prohibits retaliation against any person who raises a concern in good faith or assists with an investigation. Good-faith reporting is protected even where an investigation later determines that the concern could not be substantiated.

Any employee, officer, representative, contractor or partner found to have retaliated against a whistleblower may face disciplinary, contractual or other appropriate action, up to and including termination of employment, contract or engagement.

7. Investigation process

  1. Intake: Reports are received, logged and acknowledged where contact information is provided.
  2. Preliminary review: The concern is assessed for credibility, urgency, risk, potential impact and whether a full investigation is required.
  3. Investigation: A designated team may include compliance, legal, HR, senior management, external counsel or independent specialists, depending on the nature of the concern.
  4. Findings: Findings are documented and reviewed by appropriate management or governance personnel.
  5. Action: Corrective, disciplinary, remediation, regulatory or law-enforcement action may be taken where required.
  6. Feedback: Where possible and lawful, feedback may be provided without breaching confidentiality, privacy, legal privilege or the rights of other persons involved.

8. Confidentiality

All whistleblower reports and related investigations will be handled confidentially to the fullest extent possible. Information will only be disclosed on a need-to-know basis and where necessary for review, investigation, resolution, governance reporting, regulatory engagement, legal compliance or law-enforcement cooperation.

While we will take reasonable steps to protect the identity of a whistleblower, confidentiality may be subject to legal, regulatory, court, audit or investigation requirements.

9. Responsibilities

  • Employees and third parties: Report suspected misconduct promptly and cooperate honestly with investigations.
  • Managers and supervisors: Encourage open communication, escalate concerns appropriately and prevent retaliation.
  • Whistleblower Officer: Receive, log, assess, investigate, monitor and track whistleblower reports while maintaining confidentiality.
  • Senior management: Review investigation outcomes, support remediation and enforce corrective action where necessary.
  • Board or governance committee: Provide oversight for significant whistleblower matters and monitor the effectiveness of this Policy.

10. Record keeping

Records relating to whistleblower reports, investigations, findings and corrective actions will be retained for a minimum of seven years, or for a longer period where required by applicable law, regulation, litigation hold, audit requirement or internal governance standard.

11. Policy review

This Policy will be reviewed at least annually, or sooner where required by changes in law, regulation, business operations, organisational structure, risk exposure, regulatory guidance or internal governance requirements.

12. Contact details

For whistleblower reports or questions relating to this Policy, please contact us through any of the channels below: