[Company Logo][Company Name]
- Policy No.:
- [Reference Number]
- Version:
- [Version Number]
- Effective Date:
- [Date]
- Policy Owner:
- [Ethics / Vigilance Officer]
1. Purpose
[Company Name] encourages directors, employees and stakeholders to raise genuine concerns about wrongdoing without fear. This policy provides safe channels and protects those who report in good faith.
2. Scope
It is open to directors, employees, contract staff, vendors and customers. It covers concerns about the company's business, not personal grievances, which are handled under the Grievance Policy.
3. Definitions
- Whistleblower: a person who reports a concern under this policy.
- Protected disclosure: a report made in good faith about suspected wrongdoing.
- Ethics Officer: [Name], responsible for receiving and coordinating investigations.
4. Policy
Concerns that may be reported include fraud, theft or embezzlement; bribery or corruption; manipulation of accounts or records; breach of law or regulation; serious health, safety or environmental risks; leakage of confidential or personal data; abuse of authority; and serious breaches of the Code of Conduct.
- Reports may be made by email to [Ethics Email], hotline [Phone Number], or letter marked 'Confidential' to [Address]. Concerns involving senior management may be sent directly to the [Audit Committee Chair / Board] at [Email].
- Anonymous reports are accepted and will be examined if they contain enough detail.
- The identity of the whistleblower is kept confidential and shared only where necessary for investigation or required by law.
- No whistleblower acting in good faith will be dismissed, demoted, harassed or otherwise retaliated against.
- Deliberately false reports made with malicious intent may lead to disciplinary action.
5. Procedure
- The Ethics Officer acknowledges the report within [Number] working days where contact details are available.
- A preliminary review decides whether the concern falls under this policy.
- An investigator independent of the area concerned is appointed; the subject is given an opportunity to respond.
- Investigation is completed within [Number] days where possible; findings and actions are recorded.
- The whistleblower is informed that the matter has been addressed, subject to confidentiality.
- A summary of reports and outcomes is presented to the [Audit Committee / Board] every [Number] months.
6. Responsibilities
- Employees: report genuine concerns promptly and cooperate.
- Ethics Officer: receive, record, coordinate and protect identities.
- Investigators: act impartially.
- Audit Committee / Board: oversee the mechanism.
7. Non-compliance
Anyone who retaliates against a whistleblower, breaches confidentiality or obstructs an investigation will face disciplinary action, up to termination.
8. Review & Approval
This policy is reviewed annually and approved by the [Board / Audit Committee].
Approved by
[Authorised Signatory][Designation]Date:
[Date]Ethics Officer
[Name]Date:
[Date]