Whistleblowing Policy

At Sorbonne University Abu Dhabi (SUAD), we are deeply committed to fostering an environment of integrity, honesty, and transparency. We maintain a zero-tolerance policy for all forms of malpractice, fraud, and unethical behavior. This Whistleblowing Policy underscores our dedication to upholding the highest standards of business and personal ethics across our entire community, including all staff, faculty, students, and external stakeholders.

All members of the SUAD community and our stakeholders are expected to adhere to the highest standards of honesty and integrity in their duties and responsibilities. This includes strict compliance with all applicable UAE laws and regulations. To ensure our community is well-informed, SUAD prioritizes training on this Whistleblowing Policy and its proper usage. We encourage everyone to participate in the awareness sessions offered by the Human Resources Department to gain valuable knowledge.

This policy establishes a confidential and effective process for reporting any suspected unlawful or unethical conduct within SUAD. This includes, but is not limited to, malpractice, misconduct, and fraud.

Important Note: This policy does not cover personal grievances concerning an individual's terms and conditions of employment, complaints of bullying or harassment, or disciplinary matters. These issues are addressed under existing HR Policies and the Code of Conduct. If, during an investigation, a concern is raised that relates more appropriately to a grievance, bullying, harassment, or disciplinary matter, those procedures will be invoked in addition to, or instead of, this policy.

SUAD is dedicated to protecting individuals who, in good faith, report instances of unacceptable or improper conduct. "Good faith" means the whistleblower genuinely believes the reported information is true and accurate, based on reasonable grounds, and not motivated by malice, personal gain, or other improper motives.

Any SUAD employee who engages in whistleblowing will be shielded from retaliation. Retaliation occurs when an employer takes adverse action against an employee because they have blown the whistle. Adverse actions include, but are not limited to:

• Demotion
  
  
• Suspension
  
  
• Termination
  
  
• Failing to hire or consider for hire or promotion
  
  
• Failing to give equal consideration in employment decisions or to make impartial employment recommendations
  
  
• Adversely impacting working conditions or otherwise denying any employment benefit to an employee
  
  
• Creating a hostile or intimidating work environment

SUAD prohibits retaliation even if the concerns raised are not confirmed after an investigation. However, an employee may face adverse action if they knowingly made a false allegation, provided false or misleading information during an investigation, or otherwise acted in bad faith.

This anti-retaliation policy does not exempt any member of the SUAD community from the consequences of their own misconduct or inadequate performance; self-reporting such issues is not whistleblowing. This policy also does not prevent SUAD from managing employee performance and addressing conduct issues after an employee has engaged in whistleblowing, provided the whistleblowing activity is not the reason for the performance management.

We encourage whistleblowers to report information relating to illegal practices or violations of SUAD policies, procedures, and the code of conduct (a "Violation"), provided the whistleblower is believed to be reporting in good faith and the information indicates a Violation has occurred.

Potential Violations that can be reported include:

• Breach of professional conduct, unethical behavior, or any dishonest or fraudulent act by an employee or stakeholder.
  
  
• Disclosing confidential and proprietary information without authorization.
  
  
• Unauthorized alteration, addition, or removal of information from SUAD's records or systems.
  
  
• Fraudulent financial reporting, including manipulation of payroll or accounting records.
  
  
• Misappropriation or misuse of funds, supplies, or other assets.
  
  
• Impropriety in handling or reporting money or financial transactions.
  
  
• Destruction, removal, or inappropriate use of official records, furniture, fixtures, and equipment.
  
  
• Financial malpractice (including false payments or misuse of valuables).
  
  
• Accepting funds, favors, gifts, or kickbacks to provide undue privileges to suppliers or grant business to favored suppliers.
  
  
• Not declaring a conflict of interest.
  
  
• Creating or being involved in situations that pose a danger to the health and safety of any individual or the environment.
  
  
• Non-compliance with established internal controls.
  
  
• Discrimination on grounds of gender, race, disability, or age.
  
  
• Misuse of delegated powers or authority.
  
  
• Any similar or related Violation.

SUAD offers multiple reporting methods to ensure accessibility and encourage disclosures:

• In-Person Meeting: Schedule a personal meeting with the Internal Audit Office.
  
  
• Phone: Call the dedicated hotline at +971 (0)2 656 9555, extension 9454 / 9451.
  
  
• Email: Submit a detailed email outlining the violation to a secure mailbox accessible only by the Internal Audit Office: malek.abughosh@sorbone.apps.plana.ae
  

Reports should be directed to the Internal Audit Office. However, if the report concerns the Internal Audit Office itself, the report should be made to the Chairman of the Audit Committee through his office at sgoffice@etcc.gov.ae and/or the Vice Chancellor of Sorbonne University Abu Dhabi through the following means:

• Phone: Call the dedicated hotline at +971 (0)2 656 9100.
  
  
• Email: Submit a detailed email to a secure mailbox accessible only by the Vice Chancellor's Office: VCoffice@sorbone.apps.plana.ae

SUAD encourages its community and stakeholders to report matters directly to the Internal Audit Office using any of the listed methods. The Internal Audit Office will acknowledge the whistleblowing report within five working days.

Whistleblowers who wish to remain anonymous due to fear, pressure, or the sensitive nature of the reported violation may submit a written report detailing the suspected misconduct to the Internal Audit Office at the following address:

Internal Audit Office

Sorbonne University – Internal Audit Office

FCQ7+392 - Hazza Bin Zayed St - Al Reem Island - Tamouh

Abu Dhabi

United Arab Emirates

This policy aims to encourage and enable the SUAD community and stakeholders to report Violations for investigation and appropriate action. Accordingly, no SUAD community member or stakeholder who, in good faith, reports a Violation shall be subject to retaliation or, in the case of an employee, adverse employment consequences.

Furthermore, any SUAD community member or stakeholder who retaliates against someone who has reported a Violation in good faith will be subject to disciplinary actions as per SUAD’s disciplinary policies.