Whistleblower Policy (Staff and Non-Staff)

As a programme working for and through human rights, fundamental freedoms, and peace, SHAPE-SEA adopts a zero tolerance approach to any form of harassment, corruption, exploitation, and abuse. It is also committed to fairness and justice, where everyone enjoys freedom of expression, fairness and right to due process. In this light, SHAPE-SEA’s whistleblower policy provides a standard and mechanism for the reporting of any irregular/illegal activities, harmful practices, or the misuse of SHAPE-SEA funds and assets, while protecting the witness from retribution and/or retaliation.

Questionable Conduct

This policy is designed to address situations in which a staff or non-staff suspects anyone engaging with SHAPE-SEA programmes and operations is participating in illegal acts or questionable ethical conduct involving SHAPE-SEA assets. This conduct may include outright theft (of equipment or cash), fraudulent expense reports, sexual harassment, labour harrassment, misstatements of any accounts to any manager or to SHAPE-SEA auditors, or even a staff’s conflict of interest that results in financial harm to SHAPE-SEA but also extends to acts of corruption. SHAPE-SEA encourages staff and non-staff to report such questionable conduct and has established a system that allows them to do so anonymously if necessary.

Making and Submitting a Report

If anyone suspects illegal conduct or any conduct involving exploitation,  misuse of assets/funds, harassment, abuse, corruption, or in violation of the law, s/he may report it, anonymously if the person wishes, and will be protected against any form of reprisal harassment, intimidation, discrimination or retaliation for making such a report in good faith.

Whistleblowing reports involving staff, except directors, and non-staff engaging with the programme can be through a dedicated email, whistleblower.shapesea@gmail.com. This will be accessed by the Operations Director, who is the Human Resource point person, at any time. Any report against the directors will be brought to the Governing Board through governance.shapesea@gmail.com.

In case that report through email is exceptionally difficult and/or risky, the whistleblower can send report/letter to the following:

For cases involving staff (except Directors) and anyone engaging with SHAPE-SEA:

Operations Director
Institute of Human Rights and Peace Studies
Panyaphipat Bldg., Faculty of Social Sciences,
Mahidol University, Salaya, Phuttamonthon
Nakhon Pathom, Thailand, 73170

For cases involving Executive Director, Operations Director, and Programme Director:

Governing Board
Institute of Human Rights and Peace Studies,
Panyaphipat Bldg., Faculty of Social Science
Mahidol University, Salaya, Phuttamonthon,
Nakhon Pathom, Thailand, 73170

For purposes of initial investigation, the whistleblower is encouraged to provide the following information:

  • Person or people (staff and/or non-staff) involved in the activity
  • Details of the perceived or actual questionable ethical conduct (this can be supported by other evidences such as photos and/or videos)
  • Level of risk to the reporter/whistleblower or those affected by by the questionable ethical conduct
  • Actions already taken by the whistleblower, such as reporting to a SHAPE-SEA staff or governance body member, affiliated institution, social media, and/or enforcement agency

Admissibility and Investigation

All reports will be treated with fairness and benefit of the doubt. Upon confirmation of the initial report, SHAPE-SEA will promptly conduct a thorough investigation, which may take 30-60 days depending on urgency and level of risk. The investigating body (CMT for cases involving staff and non-staff, and appointed members of Governing Board for cases involving any directors) will be keeping the informant’s identity as confidential as possible consistent with our obligation to conduct a full and fair investigation.

Action and Penalty

In case the alleged party is a SHAPE-SEA staff, the HR policy will apply. Otherwise, the Investigation Committee will apply the same general principles outlined in the HR policy. For zero-tolerance violations, the alleged party will be required to temporarily cease operations and program-related activities during the investigation.

If the alleged person is found guilty, corrective action shall be applied immediately. Anyone who violates SHAPE-SEA core ethical principles shall immediately be terminated from work (staff) and or activity or research project (non-staff). Both the complainant and alleged party will have access to an appeals process.

Upon closure of the case, all documents related to reporting, investigation and decision making shall be filed by the PMO Team, bearing in mind that the identity of and any modes of contact with the whistleblower is deleted from all documents.

Protection of Whistleblower

Anyone who reports an incident shall be ensured that his/her/their identities are kept anonymous and confidential during and after the investigation process. No reprisals or retaliation shall be taken against the person. In cases involving staff and non-staff, the operations director shall be the person to have direct contact with the whistleblower. If the case involves any of the directors, the governing board chair or an appointed member of the Governing Board shall have direct contact with the whistleblower.