Whistleblowing Policy

Policy Statement

[company] is committed to maintaining the highest standards of ethical conduct and transparency. Our Whistleblower Policy ensures that employees have a clear mechanism for reporting concerns about unethical behaviour, illegal activities, or violations of company policies, without fear of retaliation.

Purpose

The purpose of this whistleblowing policy is to encourage current and former employees, contractual third parties or partners to communicate events that raise serious concerns about [company] or individuals who violate the organisation's policies.

Scope

This policy applies to all employees of [company], as well as contractual third parties or partners doing business with [company].

Duty to Report Misconduct

It is the duty of all employees, contractual third parties or partners to report misconduct or suspected misconduct, including fraud and financial impropriety. This includes misconducts such as but not limited to:

Providing false or misleading information, or withholding material information on [company] financial statements, accounting, auditing or other financial reporting fraud or misrepresentation;

Pursuit of material benefit or advantage;

Misappropriation or misuse of [company] resources such as funds, supplies or other assets;

Unauthorised alteration or manipulation of computer files;

Unethical business conduct in violation of any [company] policies and/or [company] Code of Ethics;

Danger to the health, safety, or well-being of employees and/or the general public;

Forgery or alteration of documents;

Authorising or receiving compensation for goods not received or services not performed, or paying for services or goods that are not rendered or delivered;

Authorising or receiving compensation for hours not worked; and

Embezzling, self-dealing, or otherwise obtaining an unlawful private benefit (i.e., [company] assets being used by anyone in the organisation improperly for personal gain).

Acting in Good Faith

Any person who files a complaint alleging misconduct must act in good faith and have reasonable grounds to believe that the information disclosed indicates wrongdoing. 

No employee, third party contractor or partner who makes a denunciation in good faith will be subject to retaliation. Retaliation is any direct or indirect harmful action that threatens a person or is taken against a person who has reported an event or action. Anyone who retaliates against a person who has made a report in good faith is subject to disciplinary action up to and including dismissal.

However, making allegations that are deemed unfounded and malicious or knowingly false may result in disciplinary action up to and including termination of employment.

Procedure

A complaint may be submitted in writing via email to their manager or senior manager.

The written statement must include the following information:

Description of the offence;

Date on which the complainant became aware of the offence;

Name of the person suspected of the offence; and

Actions taken (if applicable) before filing a complaint or allegation (i.e. talk to supervisor).

The complainant should expect to receive confirmation of receipt of the complaint within 3 working days.

The complainant will not be dismissed, demoted, suspended, threatened, harassed or otherwise discriminated against because of the communication of a genuine concern.  Any employee of [company] who contravenes this policy when dealing with a complainant may face termination.  Similarly, any member of the Board who violates this policy in his or her dealings with a complainant may have their relationship with [company] terminated.

A person is not required to prove the truth of an allegation, but is required to act in good faith and provide sufficient evidence to the person contacted to demonstrate that there are sufficient grounds for concern.  The number of contacts between the complainant and the investigative body will depend on the nature of the question and the clarity of the information provided. The investigating body may request additional information from the complainant.

All complaints will be treated in a confidential and sensitive manner. In addition, the complainant must be able to remain anonymous, except in cases where the nature of the disclosure and/or resulting investigation makes it necessary to disclose his or her identity (e. g. investigations or judicial proceedings).  In such cases, all reasonable measures must be taken to protect the complainant from any prejudice resulting from a disclosure.

Investigation

All relevant cases, including suspicious but unproven cases, will be reviewed and analysed by a competent person designated by the Managing Director. In some cases, this may involve an investigation by a legal adviser or an accountant. All investigations will be kept confidential to the extent possible. Appropriate corrective action will be taken, if necessary, and the findings will be communicated to the whistleblower and their supervisor.

Policy Review

This policy will be reviewed annually or more frequently if necessary. Updates or changes to the policy will be communicated to all relevant personnel.

Last reviewed: [insert date]