Whistleblower Policy
Introduction
This Whistleblower Policy was last modified on [April 22, 2025]
Welcome to our Whistleblower Policy
Every director, officer, employee, ambassador, volunteer, contractor and consultant of Operation
Eyesight Canada and the following organizations – Operation Eyesight Universal UK Limited, Operation
Eyesight Zambia, Operation Eyesight Universal (USA), Operation Eyesight India Trust, Operation Eyesight
Program (for Kenya) Operation Eyesight Universal, Ghana (hereinafter referred to as “Operation
Eyesight”) - occupies a position of trust.
Each individual that performs work on behalf of Operation Eyesight, including directors, officers,
employees, ambassadors, volunteers, contractors and consultants, will hereinafter be referred to as
“Representative(s)”.
Operation Eyesight is committed to the highest ethical standards. We do this by conducting our business
with integrity and by achieving full compliance with all applicable laws, rules, and regulations. In line
with this commitment, Operation Eyesight provides an avenue for Representatives to raise any concerns
they may have and to be assured that in making complaints they will be protected from reprisal for
raising their concerns in good faith.
This policy covers instances where a Representative has evidence of a violation or suspected violation
that to the best of their knowledge constitutes:
Accounting, auditing, or other financial reporting fraud or misrepresentation;
Violations of laws that could result in fines or civil damages payable by Operation Eyesight, or
that could otherwise significantly harm Operation Eyesight’s reputation or public image;
Unethical business conduct in violation of any corporate policy, including, but not limited to the
Code of Conduct;
Danger to the health, safety, or well-being of any Representative or the general public (including
any real, or perceived threat of, workplace violence or harassment).
General
Operation Eyesight’s Code of Conduct and all other policies (“the Policies”) require Representatives to
observe high standards of business and personal ethics and adhere to the Policies in their conduct of
their duties and responsibilities and in their dealings and activities.
Reporting Responsibility
It is the responsibility of all Representatives to comply with the Policies and to report violations or
suspected violations.
No Retaliation
Operation Eyesight will not permit any Representative to harass, retaliate or discriminate against others
who, in good faith, reports a violation or suspected violation. Retaliation in any form will not be
tolerated and should be reported using the channels detailed below. Any violation of this Policy may be
subject to disciplinary action up to and including termination of employment, termination of contract or
legal action.
Complaints that are not made in good faith will be viewed as a serious offence and may be subject to
discipline up to and including termination of employment or contract.
Acting in Good Faith
Any Representative who brings forward a concern or complaint relating to a violation or suspected
violation must be acting in good faith and have reasonable grounds for believing the information being
disclosed indicates a violation or suspected violation of any Policy. Any allegations that are not
substantiated and are found to be malicious, frivolous or were knowingly false will be viewed as a
serious matter and the person making such complaint or submission may be subject to disciplinary
action up to and including termination of employment or contract.
Reporting Violations or Suspected Violations
Every Representative has a duty to adhere to this Policy, all applicable policies and to immediately report
to your manager, or the Manager, Human Resources through HR@operationeyesight.com, any suspected
violations.
In most cases, your manager is the best person to address concerns. However, if you are not
comfortable speaking with your manager or you are not satisfied with the response, you are
encouraged to speak to the Manager, Human Resources through HR@operationeyesight.com, or
alternatively, to the Chair of the Governance and Nominations Committee of Operation Eyesight
Canada.
In addition to the foregoing, any Representative may report questionable accounting or auditing
matters, which may be done on an anonymous basis, by submitting a written complaint to the Chair of
the Finance, Audit and Risk Committee of Operation Eyesight Canada.
Any complaint that has been brought forward to a supervisor, manager, Manager, Human Resources
through HR@operationeyesight.com, or the Chief Executive Officer is required to be reported to the
Chair of the Governance and Nominations Committee of Operation Eyesight Canada, who has the
responsibility to investigate all reported violations or suspected violations.
Confidentiality
Concerns regarding violations or suspected violations may be submitted on an anonymous and
confidential basis. Reports of violations or suspected violations will be kept confidential to the extent
possible consistent with the need to conduct an adequate investigation.
Handling of Reported Suspected Violations or Violations
All reports of violations or suspected violations will be promptly investigated and appropriate corrective
action taken if warranted by the investigation.
Annual confirmation
All Representatives are required to sign the Whistleblower Policy annually, stating that they have
reviewed and agree to adhere to the terms of this Policy.
I acknowledge that I have been provided a copy of or access to the Whistleblower Policy. I understand the
provisions of the Policy and I agree to comply with them. I acknowledge and accept that my continued
employment or engagement is dependent upon my understanding and compliance with the Policy. I also
understand that I have an obligation to report any violation or suspected violation of the Policy.
Open Whistleblower Policy Form (PDF)
