FEIBI Whistleblowing Policy

FEIBI Whistleblowing Policy

——Upholding Integrity in Lubricant Innovation

1. Purpose & Legal Basis

FEIBI maintains this whistleblowing channel to:

Comply with:

EU Whistleblower Directive (2019/1937)

China's Anti-Unfair Competition Law (Article 7)

US Dodd-Frank Act (Section 922)

Enable confidential reporting of:

Product safety violations (e.g., falsified test data)

Supply chain misconduct (e.g., unauthorized base oil substitutions)

Financial irregularities (e.g., fraudulent customs declarations)

 2. Reporting Channels

Method

Details

Anonymity Level

Secure Web Portal

feibi.com/integrity

Full (Tor network accessible)

Encrypted Email

integrity@feibi.com (PGP Key Download)

Partial (Metadata scrubbed)

Global Hotline

+86 15823433114 (24/7, 2 languages)

Optional caller ID blocking

Note: In-person reports to FEIBI Compliance Officers require signed NDA protection

3. Investigation Protocol

Step 1: Initial Triage

Automated risk assessment (AI-powered severity scoring)

Escalation matrix:

Level 1 (Minor): Local compliance team

Level 2 (Major): Global Ethics Committee

Level 3 (Critical): Independent forensic auditors

Step 2: Confidential Inquiry

Evidence collection with blockchain timestamping

Interview protocols (remote options available)

Step 3: Resolution

Corrective actions within 60 days (extendable for complex cases)

Whistleblower feedback (unless anonymous)

 4. Protections & Guarantees

For Whistleblowers:

Strict non-retaliation policy (termination for retaliation = immediate dismissal)

Anonymous reporting: No IP logging on web portal, voice distortion on calls

Legal support fund (up to $50,000 for defense costs)

For Subjects:

Presumption of innocence until proven

Right to review allegations (redacted as needed)

 5. Special Provisions

Chemical Industry Specifics:

Lab whistleblowers may submit adulterated oil samples via secure courier

Formula theft reports trigger immediate IP lockdown

Global Operations:

Translations verified by sworn linguists

Cultural sensitivity training for investigators

 Effective Date: 1 January 2024
Policy Steward: FEIBI Chief Compliance Officer (CCO@feibi.com)

This policy supplements but does not replace legal reporting obligations to regulators

Why FEIBI's System Stands Out:

Dual Encryption: Signal protocol + quantum-resistant algorithms

Supply Chain Integration: Reports can reference batch/LOT numbers

Third-Party Oversight: Annual audits by PwC Forensic Services

"Safety isn't just in our oils—it's in our operations."
— Liang Wei, FEIBI Global Ethics Chair