WHISTLEBLOWER
1. Purpose
This policy aims to:
· Encourage persons to report an issue if they genuinely believe someone has engaged in serious wrongdoing;
· Outline how Vesco Foods will deal with all reports of serious wrong doing; and
· Set out the avenues available to persons to report serious wrongdoings to Vesco Foods.
· Whilst it is generally expected that these issues be raised through the normal channels of line management if the person is an employee, reporting by the avenues outlined in the policy may be appropriate or necessary in certain situations.
2. Scope
Vesco Foods is committed to making this policy available for activities of concern held by the following:
· All employees (both past and present) and Directors of Vesco Foods, whether full-time, part-time or casual, at any level of seniority and wherever employed;
· Employees or principals of organisations which have a commercial relationship with Vesco Foods as customers, suppliers, advisers, contractors, auditors, agents or otherwise;
· Consumers or resellers of Vesco Foods products or
· Members of the communities in which we operate
This policy will be made available to employees of the company via the Vesco Foods intranet, it will also be made available via the company website.
3. Definitions
Whistleblowing – for the purpose of this policy, Whistleblowing is defined as:
‘…the deliberate, voluntary disclosure of individual or organizational malpractice by a person who has or had privileged access to data, events or information about an actual, suspected, or anticipated wrongdoing within or by an organization that is within its ability to control’.
Whistleblower (or “Discloser”) – for the purpose pf this policy, a Whistleblower or Discloser is defined as:
…..” a person who makes, attempts to make or wishes to make a disclosure in connection with improper conduct (whether anonymously or not) and wishes to avail themselves of protection against reprisal for having made the disclosure. ….”
Improper Conduct – for the purpose of this policy, Improper Conduct is defined as:
· Corrupt, fraudulent or other illegal conduct or activity;
· A substantial mismanagement of Vesco Foods resources;
· Conduct involving substantial risk to public health or safety; or
· Conduct involving substantial risk to the environment
Issues related to Human Resources and Industrial Relations are managed under separate mechanisms and policies and procedures and are excluded from this Policy.
That would, if proven, constitute by Vesco Foods or its employee/s:
· A criminal offence;
· Reasonable grounds for dismissing or dispensing with, or otherwise terminating, the services of a Vesco Foods employee/s who was, or is, engaged in that conduct; or
· Reasonable grounds for disciplinary action
4. What is a reportable matter?
Reportable matters include any conduct that involves:
· Dishonest behaviour;
· Fraudulent activity;
· Unlawful, corrupt or irregular use of company funds or practices;
· Illegal activities (including theft, dealing in or use of illicit drugs, violence or threatened violence
and criminal damage against property);
· Improper or misleading accounting or financial reporting practices;
· A breach of any legislation relating to Vesco Foods operations or activities;
· Any other kind of misconduct or an improper state of affairs or circumstances that may cause substantial risk to public health and safety.
5. Reasonable grounds for reporting
A report may have serious consequences, including potential damage to the career prospects and reputation of people who are the subject of allegations of wrongdoing. Therefore, it is very important that those who make a report under this Policy do so with reasonable grounds for believing that the information is correct or likely to be correct.
Vesco Foods takes very seriously all reports made under this Policy and it looks particularly unfavourably on any false reports or claims. Disciplinary action may be taken against any employee who makes a report without reasonable grounds to suspect the wrongdoing. A report will not be considered to be made in good faith if it is frivolous, raised for malicious reason or ulterior motive, or if it is not based on facts and/or circumstances that provide a reasonable basis for the report. Repeated reports about trivial matters may also be considered not to be made in good faith thus not having reasonable grounds for reporting.
6. Making a report
Internal Reporting
If the Whistleblower is an employee, they should (if appropriate) first discuss the matter informally with their direct line manager or Human Resources department in order to determine whether wrong doing has occurred. This is an opportunity to clarify the incident, ask questions, and determine whether the matter comes under this policy. At all times, these discussions will remain confidential.
If the matter is based upon a personal work-related grievance it does not fall under this Policy.
Where this is not appropriate the report can be made using Vesco Foods free external independent Whistleblower service-Stopline.
External Reporting
A Whistleblower may make a report to Vesco Foods external independent Whistleblowing service using any of the following methods:
· Email to [email protected]
· Calling the hotline 1300 30 45 50 (in Australia)
· Visiting online https://vescofoods.stoplinereport.com
· By post to Vesco Foods, c/o Stopline, Locked Bag 8, Hawthorn, VIC 3122
· By fax to Vesco Foods C/o Stopline +61 3 9882 4480
An external report may be made anonymously, if desired, using any of these methods. However, this may impact Vesco Foods ability to investigate the matters reported.
7. Reports concerning the CEO and or General Manager Safety, People and Culture
If the report involves the CEO this will be directed to the General Manager Safety, People and Culture who will then in turn direct the report to the Chair of the Board. In this instance, a Whistleblower may make a report as per section 5 ‘Making a report’ and include instruction to refer the disclosure directly to the Chair of the Board.
If the report involves the General Manager Safety, People and Culture, it will be directed directly to the CEO for investigation.
8. Investigating a report
Where a report is made about a matter that comes under this policy and the Whistleblower has reasonable grounds to suspect wrongdoing, the Human Resources (HR) department will investigate the disclosure. Where the HR department deems necessary, they may use their external Whistleblower service- Stopline to conduct an investigation, either in conjunction with the HR Department or independently. All investigations will be conducted in a fair and independent manner and all reasonable efforts will be made to preserve confidentiality of the investigation.
To avoid jeopardising an investigation, an employee who has made a report under this policy is required to keep confidential the fact a report has been made (subject to any legal requirements).
9. Investigation feedback
Wherever possible, and assuming that the identity of the person making the report is known, the Whistleblower will be kept informed of the progress and outcomes of the investigation, subject to privacy and confidentiality considerations.
10. Protection of Whistleblowers
Vesco Foods is committed to ensuring confidentiality in respect of all matters raised under this policy, and that those who make a report are treated fairly and do not suffer detriment.
11. General
It is a condition of any employment or engagement by Vesco Foods that all employees must comply at all times with this Policy. However, this Policy does not form part of any agreement between any person and Vesco Foods, nor does it constitute terms and conditions of any person’s employment or engagement with Vesco Foods.
12. Review of the Policy
This Policy will be reviewed on every two years to ensure it remains consistent with all relevant legislative requirements, as well as the changing nature of the organisation. This Policy may be amended, withdrawn or replaced from time to time as the sole discretion of Vesco Foods.