Whistleblowing Policy
1. Introduction
Whistleblowing is the reporting of suspected wrongdoing in relation to our activities or a failure by Global Fishing Watch (GFW) to otherwise comply with its legal obligations. The aim of this policy is to provide an internal mechanism for reporting, investigating, and remedying any such issues.
Global Fishing Watch requires its senior leadership, managers and staff (collectively or individually,”) to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Staff must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.
2. Scope
The Whistleblowing Policy applies to all staff and External Partners of Global Fishing Watch. External Partners are our funders and collaborators, including Donors, Research Programs, Industry, Academic Institutions, International bodies including Civil Society and non-profit organizations, and Government agencies etc, with whom we have a formal relationship, a Memorandum of Understanding (MOU) or a funded project.
The GFW Whistleblowing Policy is a global policy and any local employment law requirements in relation to whistleblowing, over and above this policy and procedure, should also be applied in any location where we operate.
Appropriate subjects to report under this Policy include but are not limited to financial improprieties, accounting or audit matters, ethical violations, or other similar illegal or improper practices, such as fraud, theft, embezzlement, bribery or “kickbacks”, misuse of GFW assets, undisclosed conflicts of interest.
The Whistleblowing Policy should not be used for complaints relating to a member of staff’s personal circumstances, such as the way they have been treated at work. In those cases, staff should use the Grievance Policy & Procedure. If any member of staff has any concerns as to which policy the concern should be raised under, they should check with the Director of Risk and Compliance.
3. Purpose
The purpose of the Whistleblowing Policy (the “Policy”) is to:
- Encourage and enable Global Fishing Watch Staff to raise concerns regarding suspected illegal or unethical conduct or practices on a confidential and, if desired, anonymous basis, subject to the limitations indicated below.
- Protect Global Fishing Watch Staff from retaliation for raising such concerns in good faith.
- Establish policies and procedures for Global Fishing Watch to receive and investigate reported concerns and address and correct inappropriate conduct and actions.
4. Reporting Responsibility
Each Global Fishing Watch staff member or external partner has the responsibility to report in good faith any concerns about actual or suspected violations of Global Fishing Watch’s ethical obligations or any federal, state, or municipal law or regulation governing the Global Fishing Watch’s operations (each, a “concern”).
a. Acting in Good Faith. Anyone reporting a concern must act in good faith and have reasonable grounds for believing the information disclosed indicates a violation of law and/or ethical standards. Any unfounded allegation that proves to have been made maliciously, recklessly, or knowingly to be false will be viewed as misconduct or gross-misconduct and will be managed in line with the Disciplinary Policy & Procedure.
b. Other Types of Concerns. Global Fishing Watch Staff should refer to Global Fishing Watch’s other existing policies regarding other issues not covered by this Policy. This Policy is not intended to provide a means of appealing the outcomes resulting from other issues.
5. No Retaliation
No Global Fishing Watch Staff who, in good faith, reports a concern or participates in a review or investigation of a concern shall be subject to retaliation, or, in the case of an employee, adverse employment consequences because of such report or participation. This protection extends to Global Fishing Watch Staff who report in good faith, even if the allegations are, after an investigation, not substantiated.
Any Global Fishing Watch Staff who retaliate against someone, who in good faith has reported or participated in a review or investigation of a concern will be subject to discipline, up to and including termination of employment.
Anyone who believes that a Global Fishing Watch Staff has been subject to retaliation or adverse employment consequences as a result of making a good faith report or participating in a review or investigation of a concern should use GFW’s Reporting procedure.
6. Confidentiality
Global Fishing Watch encourages anyone reporting a concern to identify himself or herself in order to facilitate the investigation of the concern. However, concerns may be submitted on a confidential and/or anonymous basis. Global Fishing Watch shall take reasonable steps to protect the identity of the Global Fishing Watch staff, and shall keep reports of concerns confidential to the extent possible, consistent with the need to conduct an adequate investigation and to address and/or report the concerns raised. The ability to investigate and address anonymous reports may be limited by the extent of the ability to understand, investigate, confirm, and assess the credibility of the allegations raised.
7. Reporting Procedures
Any incident or concern should be reported in accordance with GFW’s Reporting procedure.
This Policy was adopted by Global Fishing Watch’s Board of Directors at its meeting on 21 Aug 2025.