Last updated: September 7, 2022
At Splash Beverage Group (“the Company”) we are committed to ensuring corporate compliance and promoting ethical corporate culture by observing the highest standards of fair dealing, honestyand integrity in our business activities.
The Company encourages the reporting of any instances of suspected unethical, illegal, corrupt, fraudulent or undesirable conduct involving the Company’s business and provides protections and measures to individuals who make a disclosure in relation to such conduct without fear of victimization or reprisal.
This policy applies to any person who is, or has been, any of the following with respect to the Company
- Contractor (including sub-contractors and employees of contractors); Supplier (including employees of suppliers);
- Consultant; Auditor; Associate; and
- Relative of any of the above
This policy is intended to apply to the above persons in all countries in which the Company operates a business.
You may make a report or disclosure under this policy if you have reasonable grounds to believe that a Company director, officer, employee, contractor, supplier, consultant or other person who has business dealings with the Company has engaged in conduct (Reportable Conduct) which is:
- Dishonest, fraudulent or corrupt;
- Illegal (such as theft, dealing in or use of illicit drugs, violence or threatened violence and criminal damage to property);
- Unethical including any breach of the Company’s policies such as the Code of Conduct; Oppressive or grossly negligent;
- Potentially damaging to the Company, its employees or a third party; Misconduct or an improper state of affairs;
- A danger, or represents a danger to the public or financial system; Harassment, discrimination, victimization or bullying.
- Company’s discretion whether it considers there is a reasonable suspicion that the Reportable Conduct is occurring and/or whether the conduct constitutes “misconduct or improper state of affairs”.
For the avoidance of doubt, Reportable Conduct does not include personal work-related grievances. A personal work-related grievance is a grievance about any matter in relation to a staff member’s current or former employment, having implications (or tending to have implications) for that person personally and that do not have broader implications for the Company. Examples of personal work-related grievances are as follows:
- An interpersonal conflict between the staff member and another employee;
- A decision relating to the engagement, transfer or promotion of the staff member; A decision relating to the terms and conditions of engagement of the staff member;
- A decision to suspend or terminate the engagement of the staff member, or otherwise to discipline the staff member.
Personal work-related grievances should be reported to your.
MAKING A DISCLOSURE
The Company relies on its employees maintaining a culture of honest and ethical behavior. Accordingly, if you become aware of any Reportable Conduct, it is expected that you will make a disclosure under this policy.
There are several ways in which you may report or disclose any issue or behavior which you consider to be Reportable Conduct.
You may disclose any Reportable Conduct to the Whistleblower Protection Officers listed below:
Chief Executive Officer
- Robert Nistico
President & Chief Marketing Officer
- William Meissner
Chief Financial Officer
- Ron Wall
You can make a disclosure outside of business hours by contacting the above Whistleblower Protection Officers via email.
You are also encouraged to contact the above Whistleblower Protection Officers to obtain any additional information you may require before making a disclosure or for any clarification regarding this policy.
The Whistleblower Protection Officer will safeguard your interests and will ensure the integrity of the reporting mechanism.
Where you do not feel comfortable making an internal report, or where you have made an internal report, but no action has been taken within a reasonable time, you may disclose any Reportable Conduct to the Company’s external independent Whistleblower OfficersPeter McDonough (Splash Board Member) & Darrin Ocasio (Partner at Sichenzia Ross Ference LLP) using any of the following Email Address:
When making a disclosure, you may do so anonymously. It may be difficult for the Company to properly investigate the matters disclosed if a report is submitted anonymously and therefore the Company encourages you to share your identity when making a disclosure, however you are not required to do so.
Where a disclosure has been made externally and you provide your contact details, those contact details will only be provided to a Whistleblower Protection Officer with your consent.
The Company will investigate all matters reported under this policy as soon as practicable after the matter has been reported. All investigations will be conducted in a fair, independent and timely manner and all reasonable efforts will be made to preserve confidentiality during the investigation.
PROTECTION OF WHISTLEBLOWERS
The Company is committed to ensuring that any person who makes a disclosure is treated fairly and does not suffer detriment and that confidentiality is preserved in respect of all matters raised under this policy.
Protection against Detrimental Conduct
The Company (or any person engaged by the Company) will not engage in ‘Detrimental Conduct’ against you if you have made a disclosure under this policy.
Detrimental Conduct includes actual or threatened conduct such as the following (without limitation):
- Termination of employment;
- Injury to employment including demotion, disciplinary action;
- Alternation of position or duties;
- Harassment, bullying or intimidation; Victimization;
- Harm or injury including psychological harm; Damage to a person’s property;
- Damage to a person’s reputation;
- Damage to a person’s business or financial position; or
- Any other damage to a person.
The Company will take all reasonable steps to protect you from Detrimental Conduct and will take necessary action where such conduct is identified. If appropriate, the Company may allow you to perform your duties from another location or reassign you to another role (at the same level) or make other modifications to your workplace or your duties to protect you from the risk of detriment.
If you are subjected to Detrimental Conduct as a result of making a disclosure under this policy or participating in an investigation, you should inform a Whistleblower Protection Officer or eligible recipient in accordance with the reporting guidelines outlined above.
Protection of Confidentiality
All information received from you will be treated confidentially and sensitively.
If you report on an anonymous basis, you will still qualify for the protections in this policy.
Where it is necessary to disclose information for the effective investigation of the matter, and this is likely to lead to your identification, all reasonable steps will be taken to reduce the risk that you will be identified.
Any employee who makes a disclosure under this policy or is implicated as a result of a disclosure that is made may access the Company’s Employee Assistance Program (EAP) which is a free and confidential counselling service.
Any breach of this policy will be taken seriously and may result in disciplinary action, up to and including termination of employment.
In so far as this policy imposes any obligations on the Company, those obligations are not contractual and do not give rise to any contractual rights. To the extent that this policy describes benefits and entitlements for employees, they are discretionary in nature and are also not intended to be contractual.
The Company may unilaterally introduce, vary, remove or replace this policy at any time.