Whistleblower Policy

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At Questionable Content, we are committed to maintaining the highest standards of integrity, transparency, and ethical behavior in all aspects of our operations. This Whistleblower Policy provides employees, partners, contractors, and other stakeholders with a safe and confidential avenue to report concerns regarding unethical or illegal digital practices, including data misuse or the improper handling of sensitive information.

We take all reports of misconduct seriously and encourage individuals to report any violations of company policy, laws, or ethical standards without fear of retaliation.

1. Scope of the Policy

This policy applies to all employees, contractors, suppliers, and other stakeholders who have a relationship with Questionable Content. It covers reports of suspected unethical, illegal, or improper conduct, particularly in the following areas:

• Data Misuse: Unauthorized access, use, sharing, or manipulation of personal, confidential, or proprietary information.
• Improper Handling of Sensitive Information: Failure to comply with data protection laws, such as GDPR, CCPA, or other regulatory standards.
• Fraud or Corruption: Involvement in fraudulent activities or corrupt practices in relation to our digital services or operations.
• Security Violations: Violations of cybersecurity policies, including the use of unsafe practices that may lead to breaches or security incidents.
• Other Unethical Practices: Any other misconduct that violates company policies or legal and regulatory obligations related to our digital operations.

2. Reporting Procedure

If you have reason to believe that unethical or illegal digital practices are taking place, you are encouraged to report your concerns through the following channels:

1. Anonymous Reporting:

If you prefer to remain anonymous, you can submit your report through a secure, anonymous platform [Insert Link to Anonymous Reporting System], which will protect your identity while allowing the company to investigate the concern.

2. Direct Reporting:

You may choose to report your concerns directly by contacting our designated whistleblower officer or compliance department:

• Whistleblower Officer: [Name and Title]
• Email: [Whistleblower Reporting Email]
• Phone: [Whistleblower Reporting Phone Number]
• Address: [Company Address]

3. Manager or Supervisor Reporting:

Employees may also report concerns to their direct manager or supervisor. Supervisors are required to escalate any reports they receive to the designated whistleblower officer or compliance department.

3. Confidentiality and Anonymity

We are committed to protecting the confidentiality of the whistleblower’s identity to the fullest extent possible. Whistleblowers have the option to remain anonymous, and all reports will be handled with the highest level of discretion. Information about the report and the whistleblower will be shared only on a need-to-know basis with individuals involved in investigating and addressing the issue.

4. No Retaliation Policy

Questionable Content strictly prohibits any form of retaliation against individuals who report concerns in good faith. This includes, but is not limited to, dismissal, harassment, demotion, or discrimination. Any employee or stakeholder found retaliating against a whistleblower will be subject to disciplinary action, up to and including termination of employment or contract.

If you believe you are experiencing retaliation as a result of making a report, you are encouraged to contact the whistleblower officer or the compliance department immediately.

5. Investigation Process

Upon receiving a report, Questionable Content will initiate a prompt and thorough investigation into the concerns raised. The investigation process may involve:

• Gathering relevant documents, records, and evidence.
• Conducting interviews with individuals who may have knowledge of the alleged misconduct.
• Coordinating with external legal or cybersecurity experts if necessary.

At the conclusion of the investigation, appropriate actions will be taken based on the findings. This may include corrective measures, policy updates, disciplinary action, or legal proceedings if warranted.

6. Good Faith Reporting

This policy is intended to address genuine concerns regarding unethical or illegal digital practices. Reports made in good faith, even if they do not result in a finding of misconduct, are fully protected under this policy.

However, knowingly making false allegations or maliciously reporting false information is a serious violation of company policy and may result in disciplinary action, including termination of employment.

7. Protection of Rights

All employees and stakeholders are encouraged to report concerns without fear of retribution. The rights of the whistleblower, as well as those of any individuals implicated in a report, will be protected throughout the process. This includes maintaining fairness, confidentiality, and the presumption of innocence until proven otherwise.

8. Training and Awareness

We are committed to fostering a culture of integrity and transparency. As part of this commitment, we provide regular training to employees and stakeholders on this Whistleblower Policy, the importance of ethical conduct, and how to identify and report unethical or illegal practices.

Employees and partners are encouraged to familiarize themselves with this policy and to actively participate in creating a safe, ethical, and compliant digital environment.

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