Whistleblower Policy

Introduction

Rocket.Chat is committed to upholding the highest standards of ethics, integrity, and transparency in all of its operations. We value the input and concerns of our employees, contractors, vendors, and other stakeholders, and we encourage them to report any suspected misconduct, unethical behavior, or illegal activities within the organization.

Using the Hearing Channel is optional. You can also use any other means available to communicate concerns or complaints.

Purpose

The purpose of this Whistleblower Policy is to establish guidelines and procedures to encourage employees and others associated with the organization to report suspected misconduct, unethical behavior, illegal activities, or other wrongdoing within the organization. The primary goal of a Whistleblower Policy is to create a safe and confidential mechanism for individuals to report concerns without fear of retaliation.

Scope

This policy applies to all individuals engaged with Rocket.Chat, including but not limited to employees, contractors, customers, vendors, volunteers, and other stakeholders.

Roles and Responsibilities

Whistleblowers: Individuals who have concerns related to misconduct or wrongdoing within the organization are enabled to report those concerns through the designated reporting channels provided in this policy. Whistleblowers are expected to provide accurate and complete information to the best of their knowledge and in good faith. People team: Is responsible for receiving and investigating whistleblower reports in a timely and impartial manner. This includes taking appropriate action to address reported concerns, maintaining confidentiality to the extent permitted by law, and ensuring protection against retaliation for whistleblowers. Executive team: Are responsible for creating an environment that encourages employees to report concerns without fear of reprisal. Make recommendations for corrective actions when necessary. Legal and Compliance Teams: The legal and compliance teams within the organization play a role in ensuring that whistleblower reports comply with applicable laws and regulations and that any necessary legal actions are taken.

Whistleblower Committee: Are responsible for determining the appropriate course of action based on investigation findings.

Guidelines

1.Reporting Mechanisms

Rocket.Chat provides a confidential reporting channel. Any individual may report concerns by completing our form associated with our company “Hearing Channel”.

Anonymous form: This form allows you to provide details of your concern while maintaining your anonymity.

It is important to reinforce that the form and any documents uploaded to it are considered restricted documents, with the utmost control over confidentiality and privacy at Rocket.Chat.

When reporting a complaint, the complainant will need to provide the following information: who, what, when, and where the irregularity occurred or will occur.

2.Reporting Categories

Complaints regarding the following matters should preferably be reported through the Hearing Channel: fraud, corruption, money laundering, conflict of interest, moral and sexual harassment, discrimination, safety, security, privacy, and cybersecurity threats at Rocket.Chat. Additionally, concerns related to environmental and health issues, conflicts of interest, or any other unethical or illegal activities within the organization are also encouraged to be reported through the same channel.

3.Confidentiality

All reports made through the reporting channel form will be treated with the utmost confidentiality to the extent permitted by law. The organization will take all reasonable measures to protect the identity of whistleblowers and those mentioned in their reports.

4.Non-Retaliation

Rocket.Chat is committed to protecting whistleblowers from any form of retaliation, including but not limited to adverse employment actions, harassment, or discrimination. Employees who report concerns in good faith will not face any negative consequences as a result of their report. Check out our “No retaliation policy” in this link.

5.Investigation Process

Upon receiving a report, Rocket.Chat will initiate a thorough and impartial investigation. The investigation may be conducted internally. If necessary, an independent third party may be hired depending on the nature and complexity of the concern. After the investigation, it might trigger appropriate disciplinary action, up to and including termination, removal from boards or committees, as well as potential criminal charges.

6.Protection Against False Reports

Reports made in good faith will be protected under this policy. However, it is important to note that individuals who knowingly make false or malicious reports, with the intent to deceive or cause harm, may be subject to disciplinary action.

7.Legal Protections

Whistleblowers may be entitled to legal protections under applicable laws and regulations. The organization will cooperate fully with authorities if the report involves potential illegal activities.

8.Recordkeeping

Rocket.Chat will maintain records related to whistleblower reports and investigations in compliance with applicable laws and regulations.

9.Reporting to Authorities

In cases where the report involves potential illegal activities, Rocket.Chat may report the matter to appropriate external authorities.

10.Review and Updates

This policy will be reviewed periodically and updated as necessary to ensure its effectiveness and compliance with relevant laws and regulations.