Whistleblowing Policy

1. Purpose

To make sure that anyone who wants to report misconduct, unlawful acts or ethical breaches they have seen at hangel or in the Association's activities can do so safely and is protected from retaliation.

2. Scope

Who can report: the Association's employees, former employees, candidates, volunteers, Board members, suppliers, representatives of organisations on the platform, users and the public.

What can be reported: bribery and corruption, irregularities in amounts due to NGOs, false records or documents, personal data breaches, discrimination, harassment, abuse, the safety of children and vulnerable groups, hidden conflicts of interest, misuse of platform permissions and breaches of the law.

For individual content reports on the platform (for example a post), the in-app "Report" button is faster.

3. Principles

1. Confidentiality. The reporter's identity is not shared without their permission unless the investigation strictly requires it.
2. Anonymous reporting. Reports can be made without giving a name; anonymous reports are also examined.
3. No retaliation. No one who reports in good faith may be dismissed, moved, excluded, stripped of platform permissions or otherwise retaliated against. Anyone who retaliates is also subject to sanctions.
4. Impartiality. Anyone connected with the subject of the report does not take part in the review. The person reported is given the chance to respond.
5. Bad faith. Anyone who knowingly makes a false report does not benefit from this policy's protection.
6. Reference framework: We follow the EU Whistleblower Protection Directive (2019/1937) as a good-practice reference; the relevant legislation in Türkiye remains applicable.

4. Roles and responsibilities

• Receiving officer (the person who monitors kvkk@hangel.org): records the report, protects confidentiality and passes it to the Board of Directors, or to the Supervisory Board if the report concerns a Board member.
• Board of Directors: assigns a member with no connection to the subject, or an external person, to review the report and decides.
• Supervisory Board: reviews reports concerning Board members.

5. How it works at hangel today

• Reports are made by e-mail to kvkk@hangel.org with "Whistleblowing — Confidential" (Turkish: "İhbar — Gizli") in the subject line. Anyone who wants to stay anonymous can use an e-mail address that does not reveal their identity.
• If the report concerns members of the Board of Directors, it can also be sent in writing to the Association's Supervisory Board at the Association's registered address.
• For confirmed breaches, measures include a warning, removal from duties, termination of contract, removal of platform permissions and, where needed, referral to the competent authorities.

6. Not yet in place and our goals

• There is no encrypted online form for anonymous reports; setting one up is a goal.
• There are no written deadlines yet for acknowledging reports and sharing the outcome. Our goal: acknowledge receipt within 7 days and give the first assessment within 3 months.
• We do not publish annual, non-identifying statistics on reports.
• There is no independent channel where reports are received by a separate party (external hotline).

7. How to raise a concern

kvkk@hangel.org (subject "Whistleblowing — Confidential"). For matters concerning Board members: the Association's Supervisory Board, at the Association's registered address. Where a crime may be involved, you retain the right to go directly to the competent authorities.

8. Review

At least once a year and whenever lessons are learned from handling a report.

9. Related documents

Code of Ethics · Anti-Bribery and Corruption Policy · Complaints and Appeals Policy · Existing "Whistleblower Policy" (contracts: whistleblower-politikasi)