Objectives and Definitions

Objectives of the Whistleblowing Policy

The purpose of this Policy is to define a clear, transparent, and secure framework for processing reports of serious facts or behaviors likely to constitute Wrongdoing.

It aims to:

• Facilitate the Reporting of serious facts in compliance with the values of integrity and responsibility.
• Guarantee the protection of the persons involved, whether they are the author of the Report or the subject of it.
• Ensure impartial and confidential processing of alerts to preserve trust and safety within the IFS community.

This policy provides members of our community with a formal internal channel within the school to report serious concerns.

Definitions

Wrongdoing: Any act that violates laws or school rules and regulations, including but not limited to:

• Dishonest, fraudulent, corrupt, or illegal conduct and practices;
• Actions involving coercion, discrimination, or harassment toward a staff member or any of the IFS stakeholders (parents, subcontractors, students, etc.);
• Any conduct dangerous to the health, safety, or security of the school and its community;
• Any other behavior contrary to ethics and public decency.

The IFS Whistleblowing Committee is the internal body responsible for handling Reports made under the whistleblowing procedure.

This committee brings together the management and governance bodies of the IFS to ensure a cross-functional vision and is composed of ex-officio members, in particular:

• The Executive Director (or their representative)
• The Principal/Proviseur (or their representative)
• The President of the Executive Board (or their representative)
• The Head of the Governance Commission (or their representative)
• The Human Resources Director (or their representative)

The Committee may consult internal or external experts if necessary.

Whistleblower: Any person linked to the IFS who, in good faith and without malicious intent, reports through the designated channels serious facts of which they are aware and which they reasonably believe constitute Wrongdoing.

Reporting: The action by which a person informs the IFS, via the provided channels, of serious facts or behaviors likely to constitute Wrongdoing. This includes actions contrary to laws, school rules and regulations, or ethics (fraud, corruption, harassment, discrimination, health and safety violations).

The Report must be made in good faith, respecting confidentiality and the protection of individuals, to allow for an impartial investigation and the implementation of appropriate measures.

Scope

This policy applies to all persons connected to the IFS: employees, former employees, candidates, subcontractors, consultants, parents, students, volunteers, etc.

It covers all Reports received by the IFS, without time limits, and does not exempt the reporter from reporting to competent authorities if necessary.

Reporting Procedure

To ensure neutrality and confidentiality in handling alerts, IFS outsources the procedure using a platform and processing managed by two external providers:

All Reports must be filed via the Whistlelink platform, accessible at the dedicated IFS address: https://ifs.whistlelink.com/

Submission is done:

• via a secure form,
• allowing for anonymity (optional),
• with guaranteed encryption and technical traceability.

To allow for a thorough analysis and effective, fair processing, Whistleblowers are encouraged to provide details as precise as possible, such as observed facts, dates, locations, persons involved, and any documents or tangible evidence.

The external provider H-Inceptio manages the receipt and preliminary investigation of Reports, as well as communication with the Whistleblower.

If the Whistleblower chooses to remain anonymous, exchanges take place via the platform without revealing their identity.

The investigation is conducted by impartial individuals independent of the IFS.

If an IFS member receives a Report directly (verbally or by email), they must immediately direct the person to the Whistlelink platform, referring to this policy, without performing any prior analysis.

Processing of Reports

Processing Steps

Receipt and Investigation 

These are handled by H-Inceptio via Whistlelink. Alerts that do not constitute a Report within the meaning of this policy will be redirected to the relevant internal departments.

In the event of a Report that complies with the criteria of this policy, an automatic notification is sent to the Human Resources Department. If the Report concerns the HR department or is likely to involve a member of that department, a request for the recusal of the HR Director is made to avoid any conflict of interest. The Executive Director and the Principal are then informed of the Report.

Processing Times

• Acknowledgment of receipt: within 48 hours (managed by H-Inceptio).
• Qualification and referral: within 5 working days from the submission of the Report.
• Investigation: Investigations are conducted diligently within a reasonable timeframe, proportionate to the complexity of the case, with regular progress updates provided to the whistleblower via the platform.

Transmission of the Report

The final report is transmitted by H-Inceptio to the Whistleblowing Committee. If the Whistleblower wishes to remain anonymous, H-Inceptio will only transmit a redacted report stripped of any data allowing for their identification.

Role of the Whistleblowing Committee

The IFS Whistleblowing Committee:

• Reviews the report;
• Takes all necessary measures;
• Informs the Executive Committee.

Upon receipt of the report or at the recommendation of the HR Department, the Committee evaluates the need for interim measures intended to protect the whistleblower and/or the potential victim (temporary suspension, no-contact orders, organisational adjustments, etc.).

When a member of the Committee or Management is directly or indirectly involved in a Report, they shall not participate in discussions or decisions related to the investigation.

When the investigation concludes that the Report is well-founded, the Committee proposes or implements appropriate corrective or disciplinary measures proportionate to the severity of the facts, which may include referring the case to competent authorities in accordance with legal and regulatory obligations.

Feedback to the Whistleblower

At the end of the investigation, a summary of the findings and decided measures is communicated to the Whistleblower, within the limits of confidentiality requirements.

Confidentiality

Anyone wishing to report a fact under this procedure has the right to have their Report handled confidentially. Every effort will be made to preserve the identity of the whistleblower.

However, when the protection of a person’s physical integrity requires it, this confidentiality may be lifted to the extent strictly necessary and in accordance with applicable legal obligations.

If the investigator needs to know the identity of the person who filed the Report, the necessity of this disclosure will be discussed with them beforehand.

Reports must be made in writing, rather than orally, to allow for the verification of the credibility of the allegations. An investigation may prove more difficult or impossible if additional information cannot be obtained from the whistleblower when necessary.

Protection of Whistleblowers

Persons fearing potential retaliation in the event their identity is revealed are invited to state this when filing their Report.

No retaliatory measures, direct or indirect, may be taken against a person who has made a Report in good faith.

Any act or behavior likely to be interpreted as retaliation must be reported to the Whistleblowing Committee, which will examine whether to initiate measures against the alleged perpetrators.

Conversely, manifestly malicious Reports may also be subject to sanctions.

Personal Data Protection

All personal data collected as part of the whistleblowing process will be processed in accordance with the PDPA (Personal Data Protection Act) and the policies in effect at the IFS.

Review and Modifications

This policy will be reviewed periodically and as needed, particularly in response to significant incidents, regulatory changes, or evolving practices.
Revisions are proposed by the Legal Director and approved by the Governance Committee.