Whistle Blowing Policy


1.1 AT Worthy Technology, Inc. is committed to maintaining high standards of business conduct and ethics, as well as full compliance with all applicable government laws, rules and regulations relating to corporate reporting and disclosure, accounting practices, accounting controls, auditing practices and other processes for the prevention of fraud, bribery and corruption (collectively “Governance Concerns”). Similarly, AT Worthy Technology¬†expects all staff to maintain high standards in conducting business with honesty and integrity.

1.2 Pursuant to its charter, the Board of Directors of AT Worthy Technology¬†is responsible for ensuring that a process exists whereby persons can report any Governance Concerns relating to AT Worthy Technology. In order to carry out its responsibilities, the Board of Directors has adopted this Whistle Blowing Policy, which was further approved for implementation by the local employer (the “Policy”).

1.3 This Policy applies to all individuals working at all levels of the corporation, including directors, officers, employees, consultants, contractors, part-time and fixed-term workers, and casual and agency staff (each a “Relevant Person”).

1.4 Any questions or concerns regarding the Policy may be directed towards the chair of the Board of Director, whose contact details are set out in paragraph 12 below.


2.1 For the purposes of this Policy, “Governance Concerns” is intended to be broad and comprehensive and to include any matter, which in the reasonable and genuinely held belief of a Relevant Person, represents malpractice, is illegal, unethical, irregular or criminal, contrary to the policies of AT Worthy Technology¬†or in some other manner not right or proper. Examples would include:

(a) violation of any applicable law, rule or regulation that relates to corporate reporting and disclosure;

(b) violation of AT Worthy Technology’s Code of Business Conduct and Ethics, Anti-Bribery & Corruption Policy or Gifts Policy;

(c) fraud or deliberate error in the preparation, evaluation, review or audit of any financial statement of AT Worthy Technology;

(d) fraud or deliberate error in the recording and maintaining of AT Worthy Technology’s financial records;

(e) fraud or deliberate error in the reporting of mineral production results or mineral grade;

(f) deficiencies in or noncompliance with AT Worthy Technology’s internal policies and controls;

(g) misrepresentation or a false statement by or to a director, officer or employee of AT Worthy Technology respecting a matter contained in the financial records, reports or audit reports;

(h) deviation from full and fair reporting of AT Worthy Technology’s financial condition; and

(i) the deliberate concealment of any of the above matters.


3.1 A Relevant Person should report a Governance Concern as soon as he/she has reasonable suspicion or concern of a Governance Concern. A Relevant Person is not expected to investigate the matter personally before reporting it.

3.2 This Policy should not be used to report any personal grievance. Any complaints about a Relevant Person’s own personal circumstances (for example an employment dispute) should be pursued with his/her line manager through the ordinary grievance channels.

3.3 Any Relevant Person with a Governance Concern is encouraged to submit his/her Governance Concern in writing, by telephone or by e-mail to an appropriate supervisor. In the event the Relevant Person does not feel comfortable raising the Governance Concern with a supervisor the Governance Concern has been raised with a supervisor and yet persists, the Relevant Person may submit his/her Governance Concern in writing, by telephone or email, to:

(a) the Chief Executive Officer in the applicable operating jurisdiction (the General Manager ); or

(b) the chair of the Board of Directors.

using the contact details set out in paragraph 12 below.

In the case of reports to the Chief Executive Officer, a copy or summary of any report will be forwarded to the chair of the Board of Director.

3.4 If a Relevant Person wishes to make a report, he/she should ensure that the report includes as much detail as possible regarding the Governance Concern(s) including name(s), dates, places, a description of events that took place, the individual’s perception of why the incident(s) are a violation of this Policy (i.e., the alleged law or policy contravened), and what action the individual recommends be taken. The Relevant Person is required to maintain the confidentiality of this report and not discuss the report or the facts of the report unless required by law.

3.5 AT Worthy Technology encourages Relevant Persons to raise any Governance Concerns internally rather than raising them outside the corporation. A Relevant Person will rarely need to make such external disclosures, however, it is recognized that there may be certain situations in which a Relevant Person may need to contact outside authorities, such as a relevant regulator.

3.6 The Governance Concerns, and any personal data included therein, will not be shared with any person other than the competent persons within AT Worthy Technology, with responsibility for managing such Governance Concerns and implementing the necessary corrective actions, together with the Board of Directors and, as the case may be, professional advisers on conditions as set out in 4.4 below.


4.1 AT Worthy Technology recognizes that a Relevant Person may be concerned about the consequences of reporting a Governance Concern. The aim of AT Worthy Technology through this policy is to encourage Relevant Persons to raise concerns in good faith. AT Worthy Technology will assist Relevant Persons in doing so.

4.2 AT Worthy Technology¬†encourages all Relevant Persons to report any Governance Concerns openly. If a Relevant Person wants to raise a Governance Concern in confidence, AT Worthy Technology¬†will do its best to accommodate this and to keep the Relevant Person’s identity secret. However, it will not always be possible for AT Worthy Technology¬†to guarantee the confidentiality of the Relevant Person. When such a situation arises, AT Worthy Technology¬†will first discuss this with the Relevant Person.

4.3 AT Worthy Technology does not prefer or encourage anonymous reporting of Governance Concerns. Reporting anonymously makes it harder, for example, for investigations to be carried out and for any wrongdoing to be discovered and rectified. It is also then more difficult to establish whether any allegations are credible and have been made in good faith. A Relevant Person who is concerned about possible reprisals if his/her identity is revealed should inform one of the contacts listed at paragraph 3.3, and appropriate measures may then be taken to preserve confidentiality.

4.4 AT Worthy Technology will implement and will ensure that any entities that may assist it in the implementation of this Policy will implement, all security measures required for ensuring the confidentiality of any personal data processed under this Policy.


5.1 A Relevant Person may report a Governance Concern without fear of dismissal, other disciplinary action, retaliation or discrimination of any kind as a result of raising a Governance Concern in good faith.

5.2 AT Worthy Technology will not tolerate any retaliation against a Relevant Person as a result of raising a Governance Concern in good faith. AT Worthy Technology is committed to investigating and responding to any such allegations of retaliatory behavior thoroughly and decisively. Also, AT Worthy Technology will not tolerate any retaliation against a Relevant Person who provides assistance to the Board of Directors, the management or any other person or group, including any governmental, regulatory or law enforcement body, investigating a Governance Concern. Employees found to have engaged in retaliatory behavior may be subject to discipline up to and including termination.

5.3 Any employee who believes that he or she is being retaliated against for making a report should immediately bring it to the attention of his/her supervisor, or such supervisor’s manager for immediate investigation. In instances where the employee is not satisfied with the supervisor or manager’s response or is uncomfortable for any reason addressing such concerns to their supervisor or manager of such supervisor, the employee may contact the Chief Executive Officer or the chair of the Board of Directors using the contact details set out in paragraph 12 below for immediate investigation.

5.4 Where it is found that a Relevant Person has made a report maliciously, in bad faith, or with a view to personal gain, disciplinary action may be taken against the Relevant Person, which could potentially lead to his/her dismissal.


6.1 Where a Governance Concern is reported in the first instance to the Chief Executive Officer, it will be reviewed as soon as possible by that officer with the assistance and direction of whomever such officer thinks appropriate. The officer may, where appropriate, implement a timely resolution to the Governance Concern. However, in some cases, the officer may consider it necessary, or appropriate, to request the Board of Directors to review, assess and investigate the Governance Concern.

6.2 Once a Governance Concern is reported to the Board of Directors, either directly or through the Chief Executive Officer, it will be reviewed as soon as possible by the Board of Directors with the assistance and direction of whomever the Board of Directors thinks appropriate including, but not limited to, external legal counsel. The Board of Directors or AT Worthy Technology, as the case may be, will implement such corrective measures and do such things in an expeditious manner as deemed necessary or desirable to address the Governance Concern.

6.3 AT Worthy Technology will endeavor to conduct any investigation arising from a Governance Concern as expeditiously as possible. Any investigation may require the co-operation of the Relevant Person involved.

6.4 Where possible AT Worthy Technology will keep the Relevant Person informed of the progress in the investigation and provide feedback on its outcome if requested, however, there are situations where this will not be possible. A Relevant Person, or any other witness involved in an investigation, must treat any information he/she receives as a result of any investigation (as well as the fact of the investigation itself) as confidential.


7.1 AT Worthy Technology shall take appropriate measures to protect the personal information it receives about anybody as a result of this Policy and will only keep such information for as long as required by applicable laws and document retention policies.

7.2 The Board of Directors will retain all records relating to any Governance Concern or report of a retaliatory act and to the investigation of any such report for as long as necessary based upon the merits of the submission. The types of records to be retained by the Board of Directors will include records of all steps taken in connection with the investigation and the results of any such investigation. Such records will be held securely and confidentially by the Board of Directors.


8.1 To ensure that all Relevant Persons are aware of the Policy, they will be advised that the Policy is available on AT Worthy Technology’s website for their review. All Relevant Persons will be informed whenever significant changes are made to this Policy. All Relevant Persons to whom this policy applies will be provided with a copy of this Policy to be signed upon receipt and will be subject to, and informed about, its importance.


9.1 AT Worthy Technology may review and amend this Policy at any time. However, it is currently envisaged that the Board of Directors will review and evaluate this Policy on an annual basis to determine whether the Policy is effective in providing a suitable procedure to report violations or complaints regarding Governance Concerns.


10.1 Nothing in this Policy is intended to dissuade or stop a Relevant Person from pursuing any other legal avenue of complaint or redress as reasonably necessary in the circumstances.

10.2 AT Worthy Technology employees have the right to access and request the updating of the personal information held about them in connection with the implementation of this Policy, as well as to ascertain the purposes for which it is processed, as required by law.

10.3 Unless otherwise provided by law, AT Worthy Technology employees may object to AT Worthy Technology continuing the processing of their personal data on compelling legal grounds, for example, that the data kept was excessive or was being kept for longer than necessary.

10.4 AT Worthy Technology employees have the right not to be subjected to automated individual decisions, without such decisions being reviewed by a competent person (see paragraph 12).

10.5 If an AT Worthy Technology employee wishes to exercise the aforementioned rights, he/she may contact the Human Resource department of the applicable operating jurisdiction or the Chief Operating Officer of AT Worthy Technology or the competent court of law.


11.1 If you have any questions about this Policy please contact the Chief Operating Officer of AT Worthy Technology in the first instance.


By mail :

AT Worthy Technology, Inc.

1405 S Fern St #94527

Arlington, VA 22202

By E-mail: contact ( at ) atworthy.com 


This Policy will be posted on AT Worthy Technology’s website at: www.atworthy.com

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