Whistleblowing

Speak Up Safely

Power of Sultan Security Services and Private Guards Ltd (PSS) is committed to maintaining high standards of integrity, transparency, accountability and respect for human rights.

We provide confidential reporting channels through which employees, contractors, suppliers and other stakeholders can report suspected misconduct, unlawful activity or serious breaches of PSS policies.

PSS will take all reasonable measures to protect the identity, anonymity and employment status of anyone who raises a genuine concern in good faith. Retaliation against a whistleblower is strictly prohibited.

What Is Whistleblowing?

Whistleblowing is the confidential reporting of suspected serious wrongdoing that could affect PSS, its personnel, clients, contractors, communities or other stakeholders.

A whistleblower does not need to prove that misconduct has occurred. A concern may be reported where there is an honest and reasonable belief that wrongdoing has occurred, is taking place or may occur.

Who Can Submit a Report?

The PSS whistleblowing process is available to:

Employees and former employees;
Contractors and subcontractors;
Suppliers and vendors;
Consultants and business partners;
Client personnel;
Members of affected communities; and
Other stakeholders connected to PSS activities.

Reports may be submitted confidentially or anonymously.

What Should Be Reported?

Whistleblowing concerns may include:

Corruption or Bribery

Offering, requesting, giving or receiving bribes, kickbacks, improper payments or other personal benefits.

Fraud or Dishonesty

Falsifying, concealing or misrepresenting financial, operational, personnel or security-related information.

Illegal Activity

Conduct that may violate Iraqi law, other applicable laws or regulatory requirements.

Human-Rights Violations

Alleged abuse, mistreatment, discrimination, unlawful detention, excessive or unlawful use of force, or other misconduct during security operations.

Health and Safety Violations

Actions or failures that place employees, contractors, clients, communities or members of the public at serious risk.

Environmental Misconduct

Conduct that causes or could cause environmental harm in breach of applicable laws or PSS environmental requirements.

Conflicts of Interest

Personal, financial or business interests that could improperly influence professional judgement or the performance of duties.

Breaches of Company Standards

Serious or deliberate violations of the PSS Code of Conduct, policies, procedures or ethical requirements.

Complaints and Whistleblowing

Whistleblowing is intended for serious wrongdoing, unlawful conduct or significant ethical concerns.

Concerns about service quality, workplace disagreements or general complaints should be submitted through the separate Complaints and Grievances page.

If you are unsure which channel to use, PSS will assess the report and direct it to the appropriate process.

How to Submit a Whistleblowing Report

Confidential Email

Send your report to:

whistleblower@pss217.com

This email is the dedicated channel for written whistleblowing reports.

Dedicated Reporting Line

Contact the PSS 24/7 Operations Line:

+964 (0) 775 021 7217

You may withhold your identity if you wish to report anonymously.

Online Reporting Form

Use the confidential whistleblowing form below.

Button: Submit a Confidential Report

Direct Reporting

Employees may raise concerns directly with:

Their immediate supervisor;
Their department manager;
The HR Manager; or
An appropriate member of senior management.

Where a concern involves the Compliance Officer or senior management, it will be escalated directly to the General Manager or another appropriate independent authority.

External Reporting

Where internal reporting is inappropriate or insufficient, a concern may be reported to the appropriate regulator, law-enforcement authority or independent auditor in accordance with applicable law.

Anonymous Reporting

You may submit a report without providing your name or contact details.

Anonymous reports will be assessed in the same way as identified reports. However, withholding contact information may limit our ability to:

Request further information;
Clarify details;
Provide progress updates; or
Communicate the outcome.

To support an effective assessment, anonymous reports should contain as much specific information as possible.

Information to Include

When submitting a report, please provide:

A clear description of the suspected wrongdoing;
When and where it occurred;
Whether it is ongoing;
Names or positions of those involved, if known;
Details of any witnesses;
Supporting documents, photographs or other evidence;
Any immediate risk to people, assets or operations;
Whether the matter has previously been reported; and
Your preferred method of confidential communication, if applicable.

You should not place yourself or anyone else at risk to obtain evidence.

What Happens After a Report Is Submitted?

1. Receipt

Where contact information has been provided, PSS will acknowledge receipt of the report promptly.

Anonymous reports cannot be acknowledged unless a secure method of communication has been provided.

2. Initial Assessment

An initial review will determine:

The nature and seriousness of the concern;
Whether immediate protective action is required;
Whether the matter falls within the whistleblowing process;
Whether there is a potential human-rights or safety impact;
Whether a formal investigation is required; and
Whether the matter must be reported to an authority.

3. Investigation

Where appropriate, PSS will appoint a suitably qualified internal or external investigator.

The investigation may include:

Interviews with relevant individuals;
Review of documents and records;
Examination of financial or operational information;
Review of incident reports or available CCTV;
Site visits; and
Consultation with legal, regulatory or technical specialists.

Investigations will be conducted objectively, confidentially and without unnecessary delay.

4. Action and Resolution

Where wrongdoing is identified, PSS will take action proportionate to the seriousness of the matter.

This may include:

Corrective or preventive action;
Additional training or supervision;
Changes to procedures or controls;
Disciplinary action;
Recovery of losses;
Contractual action;
Referral to regulators or law enforcement; or
Other appropriate legal action.

5. Feedback

Where possible and appropriate, the whistleblower will be informed when the assessment or investigation has concluded.

Legal, privacy, security and confidentiality requirements may limit the information PSS can provide about individuals, disciplinary action or investigation findings.

Confidentiality

PSS will protect the identity of whistleblowers to the extent reasonably possible.

Information will only be shared with personnel or advisers who require access to assess, investigate or resolve the concern.

In some circumstances, disclosure may be required by law or necessary to protect an individual from serious harm. Where reasonably possible, the whistleblower will be informed before their identity is disclosed.

Protection from Retaliation

PSS prohibits all forms of retaliation against anyone who raises or supports a whistleblowing concern in good faith.

Retaliation may include:

Dismissal or threats of dismissal;
Discrimination;
Harassment or intimidation;
Unfavourable changes to duties or working conditions;
Loss of employment opportunities;
Contractual penalties; or
Other punitive or negative treatment.

Any suspected retaliation should be reported immediately through the dedicated whistleblowing channel. Allegations of retaliation will be treated as a serious matter and investigated separately.

Protection applies even where an investigation does not ultimately confirm the reported concern, provided the report was made honestly and in good faith.