CEO

In striving to achieve our common ambitious goal, we must follow the principles of legality, ethics, and business conduct.

Our Code of Ethics and Business Conduct defines what is acceptable and unacceptable in our relationships with colleagues, clients, government authorities, business partners, competitors, and the public.  

Sometimes, to comply with the Code,  we will have to make difficult decisions, but in the long run, this will give us a business advantage and allow us to achieve long-term stability and prosperity for our Company.

Sobirov Jurabek
CEO Freedom Broker Uzbekistan

Reporting Violations

Employees, third parties, business partners, and any other interested person who becomes aware of bribery, corruption, fraud, theft, abuse of authority, harassment, or any other possible violation of legislation, the Code of Ethics and Business Conduct, or the internal regulations of Freedom Broker Uzbekistan can report the issue to the Hotline.

Hotline Questions and Answers

1. How the Hotline Works

• The Hotline operates according to the following principles:
• Every report received will be reviewed.
• The reporter will be protected from retaliation and/or other forms of discrimination.
• On the Whispli platform and app, the reporter has the opportunity to communicate with the investigator while remaining 100% anonymous.
• The investigation will involve a narrow circle of specialists whose expertise is necessary for the review.
• The reporter will be informed of the review results within the legal framework for maintaining confidentiality.
• The Hotline and its mechanisms are not a means for settling personal scores.
• Submitting knowingly false reports is considered a serious violation and may lead to liability in accordance with applicable law.
• The Hotline is not an emergency response service. If you are in danger or the situation is an emergency, please call the appropriate services!
  

2. What to Report to the Hotline?

• Violations of applicable law, the Code of Ethics and Business Conduct, policies, and procedures.
• Any form of corruption (bribes, extortion, improper gifts to public officials, etc.)
• Safety threats, discrimination, harassment.
• Labor law violations.
• Violations in the area of information security, personal data protection, confidential, and other legally protected information.
• Conflicts of interest (nepotism, providing services to competitors, abuse of authority)
• Unfair competition.
• Violations in accounting.
• Theft, Embezzlement, fraud.
• Violations in procurement activities.
• Money laundering of criminally obtained funds, financing of terrorism.
• Other violations

3. Who can report violations?

Employees, third parties, business partners, and any other interested person who has become aware of bribery, corruption, fraud, theft, abuse of authority, harassment, or any other violation of the Code of Ethics and Conduct may report their suspicions or facts.

4. What is the reporter's (informant's) responsibility?

The reporter is responsible for the information provided in the report. A report of an alleged violation must be objective and unbiased. It must contain all essential information (facts), stating the grounds for concern, and provide supporting documents (if any). Intentionally submitting false reports is considered a serious violation and may lead to liability in accordance with applicable law: such facts, if they contain false information and if there are grounds under current legislation,  may be referred to law enforcement agencies.

5. What does "reporter protection" mean?

Any employee, counterparty, or other third party who reports in good faith should not fear termination of employment, demotion, refusal of business cooperation, persecution, or other forms of discrimination. However, the reporter is not entitled to abuse the protection provided. The protection granted to the reporter during the investigation is not a defense against disciplinary or other liability for submitting a knowingly false report.

6. How is a report registered?

The report is submitted through the website or application of the independent provider, Whispli. All records of actions taken are protected from deletion and are saved on the platform for future audits. Responsible persons from the FRHC Compliance Department  receive automatic notifications generated by the platform according to its settings. A responsible employee of the FRHC Compliance Department oversees the entire process from the receipt of the report to the decision-making.

7. Is there a regulatory timeframe for the review?

Within 5 working days from the date of receipt of the Report, a Compliance Service employee decides whether to accept the Report for review, leave it without consideration, or reject it if there are no signs of a violation, unethical or dishonest behavior, or if there is insufficient initial data. The duration of the subsequent review may vary depending on the scale, risk level, new data, and other factors affecting the investigation, but a response to your Report will be provided no later than 60 calendar days from the moment the Report is received.

8. What is the difference between anonymous and confidential modes?

In anonymous mode, it is impossible to identify the reporter. The confidentiality (non-disclosure) of the investigation and its participants must be ensured at every stage, meaning that if the reporter discloses their personal data, it will only be known to a narrow circle of people involved in the review and will not be disclosed to anyone, not even auditors.

9. How exactly is the reporter's anonymity ensured?

Anonymity is only guaranteed if the reporter uses the Whispli website or app. When registering a message, you can choose the anonymous mode (or disclose your name, email, etc.). You will then need to save the link, the assigned username (usually a fun nickname, like "Funny Zebra"), and the password, as you can later continue to communicate with the investigator through a special chat in the application.

Hotline

If you have information about possible violations or reason to believe that violations of the Code of Ethics and Business Conduct, acts of corruption, or other instances of misconduct have occurred, you can report it through the Compliance Hotline using one of the following methods: 

• Online: Follow the link and fill out the anonymous form
• QR code: Scan the QR code for quick access to the reporting system.

All reports are handled confidentially. Anonymity and protection from any form of retaliation are guaranteed.