Whistleblowing

1. Purpose

This policy provides a safe route for raising serious concerns about conduct connected with Connect Mobile. It supports early reporting, fair review, confidentiality and protection from retaliation. It is not intended to replace ordinary customer support, repayment queries or personal employment grievances unless they involve wider wrongdoing.

2. Concerns you should report

Report information you reasonably believe may show misconduct, even if you do not have complete proof.

• Fraud, theft, bribery, corruption or improper payments.
• Manipulation of applications, instalments, accounts or customer records.
• Misuse, unauthorized disclosure or deliberate concealment of personal data.
• Money laundering, sanctions breaches or other financial crime.
• Harassment, discrimination, retaliation, abuse or serious workplace misconduct.
• Unsafe, unlawful or unethical treatment of customers or purchase-plan devices.
• Conflicts of interest, procurement abuse or misuse of company resources.
• Deliberate breach of law, regulation, internal controls or a duty to customers.
• Attempts to conceal evidence or retaliate against someone who raises a concern.

3. What is not a whistleblowing report

Questions about a device, payment, application status or service experience should normally use Contact Us. Employees should use the appropriate people process for an individual grievance that does not involve wider wrongdoing. If a support complaint reveals fraud, abuse or another serious issue, it may be referred into the whistleblowing process.

4. Making a report

Send a report to support@connectmobile.co.ke with the subject ‘Confidential whistleblowing report’, or use Contact Us. Do not send passwords, PINs or one-time codes.

You may report anonymously where the available channel permits it. Providing a safe way to contact you can help investigators clarify facts and share an outcome, but you should not disclose information that would put you at risk.

5. Information that helps

Provide what you know honestly and in your own words.

• What happened and why it concerns you.
• Relevant dates, locations, transactions and people involved.
• How you became aware of the matter.
• Whether the issue is ongoing or creates an immediate risk.
• Documents or other evidence you already hold lawfully.
• Any steps already taken or people already informed.

6. Do not investigate it yourself

Do not access accounts without authority, secretly obtain protected information, confront a suspected person, put yourself in danger or interfere with evidence. Preserve information you already possess lawfully and allow authorized reviewers or public authorities to investigate.

7. Confidentiality and data protection

Reports will be shared only with people who reasonably need the information to assess, investigate or act on the concern, subject to law and procedural fairness. Absolute confidentiality cannot be promised where disclosure is legally required, necessary to prevent harm or essential to a fair investigation.

Personal data in a report will be handled under applicable data-protection law and retained only as long as necessary for assessment, investigation, action and legal obligations.

8. Protection from retaliation

Connect Mobile does not tolerate retaliation against a person who raises a genuine concern in good faith, assists an investigation or refuses to participate in wrongdoing. Retaliation may include threats, harassment, unfair treatment, dismissal, loss of opportunity or adverse action against a customer or partner.

Report suspected retaliation promptly through the whistleblowing channel. Appropriate protective or corrective action will be considered where reasonably available.

9. Good-faith and malicious reports

You will not be penalized merely because a good-faith concern is not substantiated. Deliberately false allegations, fabricated evidence or reports made primarily to harm another person may lead to appropriate action. An honest mistake is not the same as a malicious report.

10. Assessment and investigation

A report should be acknowledged where contact details are available, screened for urgency and conflicts of interest, and assigned to an appropriately independent reviewer. The response may include preservation of evidence, a formal investigation, referral to an authorized service provider, regulator or law-enforcement authority, and remedial or disciplinary action where justified.

Investigations will seek to be objective, proportionate and fair to all affected people. Details or outcomes may be limited by confidentiality, privacy, employment or legal obligations.

11. Emergency and external reporting

If there is an immediate threat to life, safety or property, contact the appropriate emergency or law-enforcement service. Nothing in this policy prevents a person from making a protected disclosure to a regulator or other authority where permitted by law.

12. Policy oversight and review

Connect Mobile will periodically review this process, address identified control weaknesses and update the policy when reporting channels, legal duties or operations change.