The Whistleblower Policy has been developed so that an Eligible Whistleblower can raise concerns regarding situations where they believe that ABCN or anybody connected with ABCN has acted in a way that constitutes serious wrongdoing, including unethical, illegal, corrupt or other inappropriate conduct.
ABCN aims to:
A whistleblower is a person who, whether anonymously or not, attempts to report misconduct or dishonest or illegal activity that has occurred in connection with ABCN, and wishes to avail themselves of protection against reprisal for having made the report.
This ABCN Whistleblower Policy applies to:
Within this policy all of these people are represented by the term Eligible Whistleblower.
ABCN expects each Eligible Whistleblower to act honestly and ethically, and to make any report on reasonable grounds and report any concerns in line with our policies.
A person may disclose any information that the person has reasonable grounds to suspect concerning misconduct in relation to ABCN; or a related body corporate of ABCN.
Reportable Conduct is any past, present or likely future activity, behaviour or state of affairs considered to be:
The following are not reportable conduct under this policy:
Whistleblowing protections will only apply to reports of Reportable Conduct.
For a report to be investigated, it must contain enough information to form a reasonable basis for investigation including:
A report must include any steps that may have already taken to report the matter elsewhere or to resolve the concern.
ABCN encourages Eligible Whistleblowers to identify themselves to the CEO or COO, however, they may opt to report their concerns anonymously.
Reports must be made by an Eligible Whistleblower to a person who is authorised by ABCN to receive whistleblower disclosures. Authorised people are:
After receiving a report, within 10 business days, ABCN will endeavour to:
If an investigation is deemed necessary, it will be conducted fairly, objectively and in a timely manner. ABCN may contact and seek the advice and assistance of its pro-bono legal services partner, Hall & Wilcox.
Any individuals who are accused of misconduct in a report will have an opportunity to respond to allegations before any adverse findings are made and before any disciplinary action is taken.
ABCN may need to speak with a whistleblower as part of an investigation. If the identity of the whistleblower is known, ABCN will endeavour to keep them informed about the status of an investigation. ABCN may not be able to investigate a disclosure if it is unable to contact the discloser.
If there is insufficient information to warrant further investigation, or the initial investigation immediately identifies there is no case to answer, the individual who reported the Reportable Conduct will be notified at the earliest possible opportunity (if they have provided contact information).
At the conclusion of the investigation, a report will be prepared outlining:
Where possible and appropriate, having regard to ABCN’s privacy and confidentiality obligations, the whistleblower will be informed of the outcome of any investigation into their concerns.
If the Eligible Whistleblower has reasonable grounds to suspect Reportable Conduct and provided that they acted honestly and ethically in making the report, ABCN will support and protect the whistleblower and anyone else assisting in the investigation. This is the case even if it turns out the concerns were mistaken.
ABCN will not tolerate any detriment inflicted on an Eligible Whistleblower because they have made or might make, a report of Reportable Conduct either internally or to an external body. Examples of a detriment include:
This protection also applies to individuals conducting, assisting or participating in an investigation.
An Eligible Whistleblower may also be entitled to the following legal protections:
A whistleblower can choose to remain anonymous while making a disclosure, and after the investigation is finalised. However, ABCN encourages all individuals to disclose their identity when raising a concern. This will assist ABCN to gather further information. If an Eligible Whistleblower chooses to disclose their identity, their details will be treated confidentially to the fullest extent possible, only allowing qualified staff to investigate any disclosures.
The whistleblowers identity will not be disclosed unless:
Anyone who knowingly makes a false report/disclosure of Reportable Conduct may be subject to disciplinary action, including dismissal. The disciplinary action will depend on the severity, nature and circumstance of the false disclosure.
The CEO will ensure this policy and procedure is monitored and reviewed at least annually or in the event of a whistleblower disclosure. This policy will be available on the ABCN website.
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