Whistleblowing Policy
Last Updated: December 2024
Overview
At Viprone Integrated Limited ("the Organisation") we are guided by our company values. These values are the foundation of how we conduct ourselves and interact with each other, our clients, partners, suppliers, shareholders, and other stakeholders. The organisation is committed to ensuring corporate compliance and promoting ethical corporate culture by observing the highest standards of fair dealing, honesty, and integrity in our business activities.
Purpose
The policy has been put in place to ensure any concerns raised regarding any misconduct or improper state of affairs or circumstances in relation to the organisation's business are dealt with effectively, securely, and appropriately.
The organisation encourages the reporting of any instances of suspected unethical, illegal, corrupt, fraudulent, or undesirable conduct involving the organisation's business and provides protections and measures to individuals who make a disclosure in relation to such conduct without fear of victimisation or reprisal.
This policy will be provided to all employees and officers of Viprone Integrated Limited upon commencement of their employment / engagement or subsequent induction or confirmation of employment.
Scope
This policy applies to any person who is, or has been, any of the following with respect to the organisation:
- Employee
- Officer
- Director
- Partner
- Contractor (including sub-contractors and employees of contractors)
- Supplier (including employees of suppliers)
- Consultant, Auditor, Associate
- Relative, dependant, spouse, or dependant of a spouse of any of the above
This policy is intended to apply to the above persons in all countries in which Viprone Integrated Limited operates a business.
Reportable Conduct
You may make a report or disclosure under this policy if you have reasonable grounds to believe that a Company director, officer, partner, employee, contractor, supplier, consultant or other person who has business dealings with the organisation has engaged in conduct (Reportable Conduct) which is:
- Dishonest, fraudulent or corrupt
- Illegal (such as theft, dealing in or use of illicit drugs, violence or threatened violence and criminal damage to property)
- Unethical including any breach of the organisation's policies such as the Code of Conduct
- Oppressive or grossly negligent
- Potentially damaging to the organisation, its employees or a third party
- Misconduct or an improper state of affairs
- A danger, or represents a danger to the public or financial system
- Harassment, discrimination, victimisation or bullying
Important Note
Reportable Conduct does not include personal work-related grievances. Personal work-related grievances should be reported to your manager or Human Resources.
Making a Disclosure
Internal Reporting
You may disclose any Reportable Conduct to our Whistleblower Protection Officer:
External Reporting
Where you do not feel comfortable making an internal report, or where you have made an internal report but no action has been taken within a reasonable time, you may disclose any Reportable Conduct to our compliance and inquiry service:
Email: [email protected]
Protection of Whistleblowers
Viprone Integrated Limited is committed to ensuring that any person who makes a disclosure is treated fairly and does not suffer detriment and that confidentiality is preserved in respect of all matters raised under this policy.
Protection from Legal Action
You will not be subject to any civil, criminal, or administrative legal action for making a disclosure under this policy or participating in any investigation.
Protection against Detrimental Conduct
The organisation will not engage in detrimental conduct against you if you have made a disclosure under this policy, including termination of employment, discrimination, harassment, or any other form of retaliation.
Confidentiality
All information received will be treated confidentially and sensitively. You may make a disclosure anonymously, and your identity will only be shared with your consent or as required by law.
Anonymity
When making a disclosure, you may do so anonymously. It may be difficult for Viprone Integrated Limited to properly investigate the matters disclosed if a report is submitted anonymously and therefore the organisation encourages you to share your identity when making a disclosure, however you are not required to do so.
Where a disclosure has been made externally and you provide your contact details, those contact details will only be provided to a Whistleblower Protection Officer with your consent.
Investigation Process
The organisation will investigate all matters reported under this policy as soon as practicable after the matter has been reported. The Whistleblower Protection Officer will investigate the matter and where necessary, appoint an external investigator to assist in conducting the investigation. All investigations will be conducted in a fair, independent and timely manner and all reasonable efforts will be made to preserve confidentiality during the investigation.
If the report is not anonymous, the Whistleblower Protection Officer or external investigator will contact you, by your preferred method of communication to discuss the investigation process and any other matters that are relevant to the investigation.
Where you have chosen to remain anonymous, your identity will not be disclosed to the investigator or to any other person and the organisation will conduct the investigation based on the information provided to it.
Where possible, the Whistleblower Protection Officer will provide you with feedback on the progress and expected timeframes of the investigation. The person against whom any allegations have been made will also be informed of the concerns and will be provided with an opportunity to respond (unless there are any restrictions or other reasonable bases for not doing so).
To the extent permitted by law, the Whistleblower Protection Officer may inform you and/or a person against whom allegations have been made of the findings. The organisation will document the findings in a report however any report will remain the property of the organisation and will only be shared with you or any person against whom the allegations have been made if the organisation deems it appropriate.
Detailed Protection Measures
Specific Detrimental Conduct Prohibited
Detrimental Conduct includes actual or threatened conduct such as the following (without limitation):
- Termination of employment
- Injury to employment including demotion, disciplinary action
- Alteration of position or duties
- Discrimination
- Harassment, bullying or intimidation; Victimisation
- Harm or injury including psychological harm
- Damage to a person's property
- Damage to a person's reputation;
- Damage to a person's business or financial position
- Any other damage to a person
Identity Protection Measures
Your identity (or any information which would likely identify you) will only be shared if:
- You give your consent to share that information; or
- The disclosure is allowed or required by law (for example where the concern is raised with a lawyer for the purposes of obtaining legal advice)
The organisation will take the following measures for protecting your identity:
- All paper and electronic documents and other materials relating to disclosures will be stored securely
- Access to all information relating to a disclosure will be limited to those directly involved in managing and investigating the disclosure
- Only a restricted number of people who are directly involved in handling and investigating a disclosure will be made aware of your identity (subject to your consent)
- Communications and documents relating to the investigation of a disclosure will not be sent to an email address or to a printer that can be accessed by other staff
- Each person who is involved in handling and investigating a disclosure will be reminded about the confidentiality requirements, including that an unauthorised disclosure of your identity may be a criminal offence
Support Available
Any employee who makes a disclosure under this policy or is implicated as a result of a disclosure may access the organisation's Employee Assistance Program (EAP) which is a free and confidential counselling service.
Where appropriate, the organisation may also appoint an independent support person from the Human Resources team to deal with any ongoing concerns you may have.
Other Matters
Any breach of this policy will be taken seriously and may result in disciplinary action, up to and including termination of employment.
In so far as this policy imposes any obligations on the organisation, those obligations are not contractual and do not give rise to any contractual rights. To the extent that this policy describes benefits and entitlements for employees, they are discretionary in nature and are also not intended to be contractual.
Viprone Integrated Limited may unilaterally introduce, vary, remove, or replace this policy at any time.
Employees are encouraged to read this policy in conjunction with other relevant organisation policies, including the Code of Conduct.
Contact Us
If you have any questions about this Whistleblowing Policy, please contact us at [email protected]
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