The data privacy regulation in Ethiopia may require that a person making a report containing personal data must be notified of certain collection and retention practices regarding the information submitted by that person.
You are being asked to read and accept the terms below. If you do not wish to accept the terms below, we may be unable to accept any information through this system and suggest you report this matter directly to your supervisor or manager or to a representative of the Human Resources, Ethic and Compliance Departments, depending on the nature of the possible violation.
1. General
This service is a web and phone-based intake system provided by ABH Partners to individuals for reporting suspected violations of laws or regulations, ABH Partners’ code of conduct or other policies
2. Confidential
This service is a confidential online reporting system that allows you to report suspected violations of law or ABH Partners’ policies, as well as other concerns you may have, to ABH Partners. If your concern pertains to a matter that, under local law, may not be accepted by ABH Partners through this service you will need to contact your supervisor or local management or a representative of the Human Resources, Legal or Ethics and Compliance Departments to report the matter.
Please be aware that the information you supply about yourself, your colleagues, or any aspect of the ABH Partners’ operation may result in decisions that affect others. Therefore, we ask that you only provide information that you believe is accurate and true.
You will not be subject to retaliation from ABH Partners for any report of a suspected violation that is made in good faith, even if it later turns out to be factually incorrect. Please be aware, however, that knowingly providing false or misleading information will not be tolerated. The information you submit will be treated confidentially except in cases where this is not possible because of legal requirements or where, for example, your name may be disclosed if legally required or in order to conduct an investigation, in which case the information will be handled sensitively. We encourage you to identify yourself in order for us to follow up with questions we may have.
3. What personal data and information is collected and processed?
This service captures the following personal data and information that you provide when you make a report:
- Your name and contact details (unless you report anonymously) and whether you are employed by ABH Partners;
- The name and other personal data of the persons you name in your report if you provide such information (i.e.: description of functions and contact details); and
- Description of the alleged misconduct as well as a description of the circumstances of the incident. Note that depending upon the laws of the country, the report may not be made anonymously; however, your personal information will be treated confidentially and will only be disclosed as set out below.
4. How will the personal data and information be processed after your report and who may access personal data and information?
The personal data and information you provide will be stored in a database at ABH Partners.
For the purpose of processing and investigating your report and subject to the provisions of local law, the personal data and information you provide may be accessed, processed and used by the relevant personnel of ABH Partners, including Human Resources, Finance, Legal, Compliance, management, external advisors legal advisors.
Personal data and information you provide may also be disclosed to the police and/or other enforcement or regulatory authorities. The relevant bodies that receive, and process personal data can be located in Ethiopia or in another country.
5. Accessing information concerning the report
ABH Partners will promptly notify any person who is the subject of a report except where notice needs to be delayed to ensure the integrity of the investigation and preservation of relevant information
6. Retention of the Report and of Your Data
Your report and your personal data will only be retained for as long as they are needed for the investigation of your allegations and for any legitimate follow-up to the investigation; they will be fully and securely destroyed or erased when and as soon as they are no longer needed for the investigation of the report, or for the purposes of legitimate follow-up to the report (including legal action). However, reports and files on the investigation of reports (or parts of such reports or files) and personal data in such reports or files may be placed in an archive if there is a clear and overriding public interest or legal interest of ABH Partners in retaining the data, including in accordance with ABH Partners’ record retention policies, subject to such restrictions on access to the data aimed at safeguarding the rights and freedoms of the data subjects as may be allowed by applicable law.
7 . Your Rights
Your report and your personal data will only be retained for as long as they are needed for the investigation of your allegations and for any legitimate follow-up to the investigation; they will be fully and securely destroyed or erased when and as soon as they are no longer needed for the investigation of the report, or for the purposes of legitimate follow-up to the report (including legal action).
However, reports and files on the investigation of reports (or parts of such reports or files) and personal data in such reports or files may be placed in an archive if there is a clear and overriding public interest or legal interest of ABH Partners in retaining the data.
8 . Transfers of Personal Data
Your report and your details may be held on the secure servers of ABH Partners. Any issues or concerns relating to topics not permitted by law to be reported via the service should be reported directly to your Manager or Supervisor or a representative of the Human Resources, Legal or Compliance Departments as appropriate for the subject matter of the possible violation. In some countries, anonymous reports may not be permitted under the law except under extremely restrictive circumstances.
9. Acknowledgement
Your report and your details may be held on the server of ABH Partners.
