Prepared By: Director Human Resources

Approved By: Chief Executive Officer

Revision Date: October 2, 2014

Effective Date: December 5, 2014


ASKY Airlines seeks to conduct itself with honesty and integrity at all times. However, we acknowledge that all organizations face the risk of their activities going wrong from time to time, or of unknowingly harboring malpractice.

The management of ASKY Airlines believes it is its duty to take appropriate measures to identify such situations and attempt to remedy them. On this basis, staff are encouraged to raise genuine concerns about malpractice in the workplace without fear of reprisals, and ASKY Airlines will protect them from victimization and dismissal.

What is Whistleblowing?

Whistleblowing consists in the raising by an employee or worker of a specific concern regarding some danger, fraud or other illegal or unethical conduct that affects others, for example other workers, the company, or members of the public. The concerns may be raised about misconduct within the organization or within an independent structure associated with it.

Who are the Beneficiaries of a Whistleblowing System?

An effective whistleblowing system protects the employees and safeguards the interests of all the stakeholders of the company as well as the interests of the public.

It enables the company to timely find out when something is going wrong and to take necessary corrective action.

Authority for this Whistleblower Policy

Overall authority for this policy sits with Director Human Resources.
All staff are responsible for the success of this policy and should ensure that they take steps to disclose any wrongdoing or malpractice of which they become aware.

What is the Purpose of this Whistleblower Policy?

The purpose of this whistleblowing policy is to establish ASKY’s whistleblowing system, to guarantee protection of whistleblowers, and to eradicate unethical and illegal practices.

By implementing this whistleblowing policy, management aims to create an atmosphere of openness and trust, and to encourage staff to play their part in improving the overall effectiveness and success of the company. Whistleblowing is therefore a positive measure that will help improve working conditions.

What is the Scope of this Whistleblower Policy?

This policy applies to all ASKY Airlines employees.

ASKY Airlines has introduced these procedures to enable employees to raise or disclose concerns about malpractice in the workplace at an early stage and in the right way, and they apply in all cases where there are genuine concerns, regardless of where this may be and whether the information involved is confidential or not.

The term 'malpractice' includes but is not exhaustive of:
- Fraud and pressures to commit or participate in fraud:
o Corruption: conflicts of interest, bribery (invoice kickbacks, bid rigging, other), illegal gratuities, funds extortion;
o Asset misappropriation: cash larceny (of cash on hand, from deposits, other), skimming (unrecorded or understated sales, false refunds, other), excess baggage fraud (incorrect weight information, amount billed but not recorded), deposit lapping, fraudulent disbursements (billing schemes, payroll schemes, expense reimbursement schemes, check tampering, register disbursements), inventory and other assets (misuse, larceny, purchasing & receiving, other);
o Fraudulent statements: financial (asset/revenue overstatements, asset/revenue understatements, timing differences, fictitious revenues, concealed liabilities and expenses, improper disclosures, improper asset valuations), non-financial (employment credentials, internal documents, external documents);
o Deliberate underperformance by colleagues;
o Dissemination of false information or release of misleading statements;
- Criminal offences (e.g.: endangering the safety of an aircraft, robbery, burglary, violent disorder, assault occasioning bodily harm, sexual assault, arson, possession of illicit substances, drug trafficking, theft, forgery and counterfeiting, fraud, etc.);
- Breaches of legal obligations (including negligence, breach of contract, breach of administrative law);
- Health and safety;
- Damage to the environment;
- The concealment of any of the above.

If an individual raises a genuine concern and is acting in good faith, even if it is later discovered that they are mistaken, under this policy they will not be at risk of losing their job or suffering any form of retribution as a result. This assurance will not be extended to an individual who maliciously raises a matter they know to be untrue.

Protection of and Support for Whistleblowers

Employees are protected against detrimental treatment (unwarranted disciplinary action, victimization, etc.) or dismissal if they raise genuine concerns about a current situation or a likely future situation, as well as situations that have occurred before the enacting of this policy.

Management is ready to act against any employee who would try to hinder another from voicing his or her concerns over malpractice.

Once a disclosure is made, a member of the HR team will be allocated as your key contact to keep you up to date with the matter and provide any specific support that you may need. If you believe that you are being subjected to a detriment within the workplace as a result of raising concerns under this procedure, you should inform your allocated HR team member immediately. Workers who victimize or retaliate against those who have raised concerns under this policy will be subject to disciplinary action.

Procedure for Raising a Concern

If you believe that the actions of anyone (or a group of people, including consultants) working for ASKY Airlines do or could constitute malpractice, you should raise the matter with Director Human Resources. Where this is not appropriate, you may raise the matter directly with the Head of Internal Audit.

You may raise your concern verbally or in writing and should include full details and, if possible, supporting evidence. You must state that you are using the Whistleblowing Policy and specify whether you wish your identity to be kept confidential.

If unable to visit physically with Director Human Resources or with the Head of Internal Audit (e.g. for those in countries other than Togo), you may:
_ Call the following telephone number: +228 22 23 05 19 / +228 99 41 08 22
_ Write a letter addressed to Director Human Resources, ASKY Airlines, EBID-ECOWAS Building, 7th Floor, 128 Bd du 13 janvier, BP. 2988 Lomé – TOGO;
_ Or send an email detailing the concern to: transparence@flyasky.com


Every effort will be made to keep your identity confidential, at least until any formal investigation is under way. In order not to jeopardize the investigation into the alleged malpractice, you will also be expected to keep the fact that you have raised a concern, the nature of the concern and the identity of those involved confidential.

There may be circumstances in which, because of the nature of the investigation or disclosure, it will be necessary to disclose your identity. If in our view such circumstances exist, we will make efforts to inform you that your identity is likely to be disclosed. If it is necessary for you to participate in an investigation, the fact that you made the original disclosure will, so far as is reasonably practicable, be kept confidential and all reasonable steps will be taken to protect you from any victimization or detriment as a result of having made a disclosure. The management will do all possible to protect the rights of all whistleblowers at all times.

How a Disclosure Will Be Handled?

All disclosures will be taken seriously and the following procedure will be used:
1. Your disclosure under this policy will be acknowledged in writing confirming that the matter will be investigated and the management will get back to you in due course.
2. A suitable person will be identified/assigned to manage the disclosure. This will be someone who is in a position to take any necessary action as an outcome.
3. Internal Audit will conduct an investigation into the allegation. The investigation will start within two weeks of the disclosure. The length and scope of the investigation will depend on the subject matter of the disclosure. In most instances, there will be an initial assessment of the disclosure to determine whether there are grounds for a more detailed investigation to take place or whether the disclosure is based on erroneous information.
4. You may be asked to provide more information during the course of the investigation.
5. The investigation report will be reviewed by the person managing the disclosure.
6. Appropriate action will be taken – this could involve initiating a disciplinary process, or informing authorities if a criminal action has been committed.
7. If it is found that there is not sufficient evidence of malpractice, or the actions of the individual(s) are not serious enough to warrant disciplinary action, it may be more appropriate for the management to take a less formal approach to dealing with the matter.
8. You will receive written notification of the outcome of the investigation, though not all the details or a copy of the report. Possible outcomes of the investigation could be that:
- The allegation could not be substantiated; or
- Action has been taken to ensure that the problem does not arise again.
9. If you are not satisfied with the response you have received, you should raise the matter with the Head of Internal Audit outlining your reasons.
10. If you have asked to remain anonymous, care will be taken to respect this request (see section on confidentiality above).

Corrective Action and Compliance

As part of the investigation into disclosures made under this policy, recommendations for change will be made by Internal Audit to enable ASKY Airlines to minimize the risk of the recurrence of any malpractice or impropriety which has been uncovered. The Director of Human Resources will be responsible for reviewing and implementing these recommendations in the future and for reporting on any changes required to the CEO.

False Disclosures

ASKY Airlines will treat all disclosures of malpractice seriously and protect staff who raise concerns in good faith. However, appropriate disciplinary action will be taken against any employee who is found to have made a disclosure maliciously that they know to be untrue, or without reasonable grounds for believing that the information supplied was accurate.

Acknowledgment and Signature

I have received the Whistleblower Policy of ASKY Airlines, which I have read and understood.

NAME: _________________________________________________________________

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