Whistleblower Policy


Ulula is committed to ensuring corporate compliance, promoting ethical corporate culture and strongly advocates a moral and transparent path in all its business affairs with clients, employees, government bodies, associates, partners, suppliers, shareholders and other stakeholders by adopting the highest standards of professionalism, integrity and ethical behaviour.

The purpose of this policy is to encourage the reporting of any instances or suspected fraudulent activities, unethical, illegal, corrupt, or undesirable conduct involving the Company’s business, spreading of misinformation or using confidential information or data in a way that works against the interests and progress of the organization to individuals or entities believed to be able to effect action – the organization itself, the relevant authorities, or the public (Whistleblowing).

This policy seeks to ensure that concerns raised/reported regarding any misconduct or improper state of affairs or circumstances in relation to Ulula’s business are dealt with effectively, securely, appropriately, and decisively and provides protections and measures to individuals who make a disclosure (Protected Disclosure).


This policy applies to all employees, consultants, contractors, sub-contractors, suppliers, auditors, clients, associates and everyone the Company interacts with and encourages all to inform of any observations or suspicions of any kind of wrong-doings by the Company’s employees or associates, which is detrimental to its reputation and respect. Any actual or potential violation of the Code of Conduct, however insignificant or perceived as such, would be a matter of serious concern for the Company.


All employees and directors of the Company are encouraged to make Protected Disclosures under this Policy by disclosing information about corruption or other wrongdoing being committed in or by Ulula to individuals or entities believed to be able to effect action or change. Protected Disclosures would mean that both the disclosures and the names of the informer will be kept strictly confidential at all times.

Any evidence such as documents, media, photographs, messages, chats, mails, etc should be provided in order to substantiate the complaint.

A whistleblower shall not be required to conduct their own investigation and prove the truth of an allegation but should  act in good faith by lodging a complaint following the appropriate channels and to the right person(s);  and also provide sufficient evidence to show that there is a reasonable basis for the complaint warranting an investigation. HR or Management on receiving the complaint will investigate further as deemed necessary. 

Reportable Conduct

Under this policy, a report or disclosure should be made if you have reasonable grounds to believe that a Company employee, contractor, supplier, consultant or other such person who has business dealings with the Company has engaged in a questionable and  reportable  conduct.

Reportable Conduct shall mean behaviour that is:

  • Questionable or unethical practises (including a breach of Ulula’s Code of Conduct and safeguarding policy)
  • Illegal (of drug use, violence or its threat, criminal damage to the company or property)
  • Violation of Federal or Provincial laws and regulations
  • Accounting irregularities or other financial reporting, bribery, fraud or misrepresentation;
  • Dangerous or represents a danger to the health, safety, or well-being of employees, volunteers, contractors, and/or members of the public, or the environment.
  • The alteration, fabrication, falsification or forging of documents, contracts or reports
  • Oppression, discrimination, harassment, victimisation or bullying, human trafficking and modern slavery
  • Misconduct or inappropriate state of affairs
  • Misuse of assets or services
  • Unauthorised access or disclosure of sensitive or personal data

Reportable Conduct does not include personal work-related grievances. A personal work-related grievance is a grievance about any matter in relation to an employee or employment, having implications (or tending to have implications) for that person personally and that do not have broader implications for the Company. Examples of personal work-related grievances are as follows:

  • Conflict between one employee and another
  • A decision on engagement, transfer or promotion
  • A decision on the terms and conditions of employment
  • A decision to discipline, suspend or terminate the engagement of an employee, consultant or contractor

Personal work-related grievances should be reported to your Manager and  HR; following the guidelines stipulated for managing grievances (see Ulula employee handbook pg. 33).

Ulula will exercise  discretion in determining whether there is a reasonable suspicion that a Reportable Conduct is occurring and/or whether the conduct constitutes “misconduct or improper state of affairs” under this policy.

Bribery and Corruption

Ulula conducts all of its business in an honest and ethical manner and takes a zero-tolerance approach to bribery and corruption.  We are  committed to acting professionally, fairly and with integrity in all our business dealings and relationships. It is therefore our goal to uphold practices and relevant laws to counter bribery and corruption; and avoid acts which might adversely reflect on the integrity and reputation of the company; and encourage all our employees, consultants, contractors and representatives at all levels to do the same .

We would ensure that individuals who receive bribes or are involved in corrupt activities are reported, investigated and subject to appropriate disciplinary action.

Making a Disclosure

Ulula relies on its employees maintaining a culture of honest and ethical behaviour. Accordingly, if you become aware of any Reportable Conduct, it is expected that you will make a disclosure under this policy.

There are several ways in which you may report or disclose any issue or behaviour which you consider to be Reportable Conduct.

Internal Reporting

You may disclose any Reportable Conduct to the following “Whistleblower Protection Officers”:

  1. Your direct Manager
  2. The Human Resources Manager – [email protected]
  3. The CEO – [email protected]

Any person who wishes to make a disclosures should discreetly get in touch with their Manager and Human Resources (HR) to inform them of the incident or observations. If the incident involves the Whistleblower’s Manager, or the Whistleblower’s manager is found to be a participant in the incident, then the employee should approach the HR Manager and/or the CEO.

Besides reporting to the named officers, you can make a disclosure by lodging an anonymous complaint by completing this anonymous whistleblower reporting form and attaching evidence of the reported conduct.

If any of the Whistleblower Protection Officers is implicated in the complaint or is unavailable, another named officer who is not implicated in the alleged Incident will manage the investigation.

The written complaint should include the following information:

  • Description of the alleged Incident;
  • Date complainant became aware of the alleged Incident;
  • Name of the individual suspected of engaging in or contemplating engaging in the alleged Incident
  • Any relevant document/evidence to support the claim; and,
  • Steps taken (if any) prior to making the complaint.

External Reporting

Where you do not feel comfortable making an internal report, or where you have made an internal report, but no action was been taken within a reasonable time, or the  action taken can be adjudged as inadequate or unfair; you may disclose any Reportable Conduct to the Board of Directors, or other entities and regulators using any of the following channels:

Whistleblower Hotlines/contact


Reportable Conduct Type

Report to

Contact details


General issues

Members of the board

[email protected]


Accounting/Financial irregularities and  bribery

Company Auditor, Lacshana Kugadasan

416-607-4179 [email protected]


Cases related to violence, harassment modern slavery and human trafficking.

HR and/or Peninsula

Email [email protected] or Call Peninsula advice line on 1-833-247-3656 and press option #2.


Employment Standards

Ministry of Labour

Toll-free: 1-800-531-5551 or Tel: 416-326-7160 or file a claim


Occupational health and safety issues

Ministry of labour

file a complaint or contact them on ​​1-877-202-0008



Tax or Benefits Fraud

Canada Revenue Agency

Report using this  CRA link


Public interest and general complaints,

Centre for Free Expression

Contact Centre for Free Expression or call them on 416-979-5000, ext 55639

Hard copy complaints ( with relevant documentation/evidence) can also be sent and addressed to any of the listed officers/offices) and marked as CONFIDENTIAL.  The name of the officer it is attentioned to must be written on the envelope as well, to ensure it is delivered strictly to the addressed officer:

Ulula Canada Inc. Unit 1005
317 Adelaide Street West 
Toronto, ON M5V 1P9

Ulula France
9 rue de Conde
33000 Bordeaux

The concerns raised by a Whistleblower will be captured in a report. Any information contained in the report will be kept confidential, except as required by law or where a disclosure is necessary to regulatory authorities, law enforcement agencies or professional advisors to the Company.In extreme situations, where the conduct or wrongdoing may be of such gravity that you have reasonable grounds to believe that the information concerns substantial and imminent danger  to the public, health or safety of the company or one or more persons, or to the natural environment and you have made a disclosure internally to the right officers and  have also given adequate information, without resolution, you may decide to make a public interest disclosure to a third party and/or industry regulator. You may also choose to discuss your concerns with a legal practitioner for the purposes of obtaining legal advice or representation. You will be covered by the protections outlined in this policy if you have reported your concerns to an appointed third party or a legal practitioner.

 Anonymous Reporting

You may choose to make a disclosure anonymously. It may be challenging however, for the Company to properly investigate disclosed issues,  if a report is submitted anonymously. Ulula therefore encourages you to share your identity when making a disclosure, although  you are not required to do so.

Where a disclosure has been made externally and you provide your contact details, those contact details will only  be provided to a Whistleblower Officer with your consent

  • Where an employee, consultant, volunteer, or contractor reasonably suspects that an Incident has occurred or will occur, the employee, volunteer, or contractor may submit a written complaint to any of the whistleblower protection officers. (See section on “Making a disclosure”)
  • All Protected Disclosures concerning financial/accounting matters should be addressed first to the CEO, and in his absence or if the CEO is implicated in the complaint, then the Board of Directors of the Company for investigation. All other reportable conducts and complaints should be registered with HR.
  • If a Protected Disclosure concerning financial/accounting matters is received by any executive of the Company, the same should be forwarded to the CEO and/or the Board of Directors. Appropriate care must be taken to keep the identity of the Whistleblower confidential.
  • Protected Disclosures should preferably be reported in writing so as to ensure a clear understanding of the issues raised and should either be typed or written in English or in the regional language of the place of employment of the Whistleblower.
  • Protected Disclosures, including non-compliance with our safeguarding policy should be factual and should contain as much specific information as possible to allow for proper assessment of the nature and extent of the concern and the urgency of a preliminary investigation.
  • The Whistleblower may or may not disclose his/her identity in such Protected Disclosures. Anonymous disclosures will also be entertained. However, it may not be possible to interview the Whistleblower and grant him/her protection under the policy.
  • If the report is not anonymous, the Whistleblower Protection Officer(s) or external investigator will contact you, by your preferred method of communication, to discuss the investigation process and any other matters that are relevant to the investigation.
  • Where you have chosen to remain anonymous, your identity will not be disclosed to the investigator or to any other person and Ulula will conduct the investigation based on the information provided.
  • While it will be ensured that genuine Whistleblowers are accorded complete protection from any kind of unfair treatment, any abuse of this protection will warrant disciplinary action.
  • Protection under this Policy would not mean protection from disciplinary action arising out of false or bogus allegations made by a Whistleblower knowing it to be false or bogus or carried out in bad faith or with an intent to deceive.
  • Whistleblowers who make Protected Disclosures on a regular basis which have been subsequently found to be frivolous, baseless, malicious and carried out in bad faith or with intent to deceive will be disqualified from reporting further Protected Disclosures under this Policy. In respect of such Whistleblowers, Ulula would reserve its right to take appropriate disciplinary action.

Investigations will be launched only after a preliminary review establishes that the alleged act constitutes an improper conduct or unethical activity and is substantiated enough for an investigation to be conducted by a committee

  • All reportable conduct under this Policy will be thoroughly investigated by a committee set up to address the concerns raised (Audit Committee). The committee will be constituted by the CEO and should represent different levels of Management, including junior level employees, and preferably in odd number headcount (eg. 3,5,7). Investigations will be conducted in a fair, independent and timely manner and all reasonable efforts will be made to preserve confidentiality during the investigation.
  • If any member of the “Audit Committee” has a conflict of interest, then such a member should recuse himself/herself and the other members of the Audit Committee will deal with the reported conduct. In cases where Ulula is not required to constitute an Audit Committee, the CEO and/or the Board of Directors shall investigate or nominate a Director to investigate the reported conduct.
  • The Audit Committee may at its discretion, consider involving an external investigator for help with the investigation.
  • The decision to conduct an investigation by the Audit Committee is by itself not an accusation and is to be treated as a normal fact-finding process, as the outcome of the investigation may not support or may not specifically align with the conclusion of the Whistleblower.
  • The identity of the accused will be kept confidential to the extent possible given the legitimate requirements of law and the policy.
  • The alleged accused person will normally be informed of the allegations at the outset of a formal investigation and will have opportunities to provide their inputs or defence during the investigation.
  • The alleged accused person shall have a duty to co-operate with the Audit Committee or any of the internal / external investigators.
  • The alleged accused person has a right to consult with a person or persons of their choice, other than the members of the Audit Committee and/or the Whistleblower; and be free at any time to engage external counsel at their own cost to represent them in the investigation proceedings.
  • The alleged accused person has a responsibility not to interfere with the investigation. Evidence shall not be withheld, destroyed or tampered with and witnesses shall not be influenced, coached, threatened or intimidated.
  • Unless there are compelling reasons not to do so, the alleged accused person will be given the opportunity to respond to material findings contained in an investigation report(unless there are any restrictions or other reasonable bases for not doing so)..
  • Where possible, the Whistleblower Protection Officer will provide feedback on the progress and expected timeframes of the investigation to the Whistleblower as well as the person against whom any allegations have been made
  • The alleged accused person has a right to be informed of the outcome of the investigation. If allegations are not sustained, the accused person should not continue to be treated as a suspect.
  • The final report will remain the property of Ulula and will be shared with the Whistleblower or any person against whom the allegations have been made if the Company deems it appropriate while respecting the privacy of individuals involved and the confidentiality of business information..
  • Efforts should be made to complete the investigation within 3 months of the receipt of the reportable conduct, and may be shorter or longer depending on the issue being investigated.
Investigator’s Role

Investigators can be internally constituted or externally contracted. Ulula mandates that Investigators are required to conduct a process towards fact-finding and analysis and will exercise their authority for specific access rights to data/information, property, buildings, technical and other resources, when acting within the scope of their investigation.

All Investigators shall be independent and unbiased both in fact and as with perceived notions. Investigators have a duty of fairness, objectivity, thoroughness, ethical behaviour and observance of legal and professional standards.

  • No unfair treatment will be meted out to a Whistleblower by virtue of having made a Protected Disclosure under this Policy. Ulula condemns any kind of discrimination, harassment or victimization or any other unfair employment practice being adopted against Whistleblowers. The Company will take steps to minimise difficulties which the Whistleblower may experience as a result of making the Protected Disclosure. If the Whistleblower is required to give evidence in criminal or disciplinary proceedings, Ulula will arrange for the Whistleblower to receive advice about the procedure.
  • Any other employee assisting in the said investigation shall also be protected to the same extent as the Whistleblower.
  • The identity of the Whistleblower shall be kept confidential to the extent possible and permitted under law. Whistleblowers are cautioned that their identity may become known for reasons outside the control of the Audit Committee (for instance, during investigations carried out by external Investigators, etc).
  • For greater certainty, Whistleblowers will not be discharged, demoted, suspended, threatened, denied an opportunity or benefit, harassed, or in any other manner discriminated against as a result of reporting a genuine concern.
  • Where an individual believes that they have been retaliated against for submitting a complaint in good faith under this Policy, they may submit a follow-up complaint in respect of the alleged retaliation in accordance with the procedure for reporting complaints outlined in this Policy. The retaliation complaint will be investigated according to the investigation procedure set out in this Policy.
  • Any individual who is found to have retaliated against an individual for reporting a complaint in accordance with this Policy will be subject to discipline. 
  • Nothing in this Policy restricts the Company from taking disciplinary action or steps to manage the performance of any employee, Consultant, or contractor for reasons that are not connected to a good faith complaint made pursuant to this Policy.

Any other employee assisting in the said investigation shall also be protected to the same extent as the Whistleblower.


If an investigation led by the Audit Committee concludes that an improper unethical act has been committed, the Audit Committee shall recommend to management to take such disciplinary or corrective action as they deem fit. Any disciplinary or corrective action initiated against the alleged accused person, as a result of the findings of an investigation shall be adhered to.


Ulula reserves its right to amend or modify this policy at any time without assigning any reason whatsoever.

Any deviation to this policy has to be approved by Management.

Non-compliance and consequences

Violation of this policy is subject to disciplinary action, up to and including termination.