JFE Global Pty Ltd and JFE Global (NZ) Ltd (together as “Fisher Leadership”) is committed to the highest standards of conduct and ethical behaviour including compliance with the legal environment in which we operate. To reinforce this commitment, we encourage the reporting of any instances of suspected breaches of our Code of Conduct, including any unethical, illegal, or undesirable conduct involving Fisher Leadership or any of its representatives (including employees and associates). It is important that people feel safe in speaking up, so Fisher Leadership will provide protections so that anyone making a report may do so without fear of reprisal, intimidation or disadvantage.
Goal of this policy
The goal of this policy is to provide very clear guidelines on how we approach and manage this feedback. With our whistleblowing policy, we aim to ensure:
- Everyone should have the chance to speak up when they feel we are not adhering to our corporate values and standards. They should have a place to report misconduct, every report will be heard and acted on, and we will make improvements based on the results.
- Everyone should be able to make reports anonymously. We commit to protecting informant’s identities and they only need to reveal themselves if they choose to.
- We will investigate every report of misconduct. At the end of the investigation, we will document the results and provide feedback when appropriate.
What conduct should be reported
We want to hear from you if you witness or know about any behaviour that is:
- Violates the law or any legal code;
- Is creating an unsafe environment;
- Breaches any of our company’s policies;
- Harassment and/or bullying of any kind;
- Any conduct which is detrimental to Fisher Leadership and could cause financial or non-financial loss.
Process for making a report
If a person would like to make a report, they have different channels available where they can do this.
- Speak with a member of the leadership team
- Speak with a member of the Board of Directors
- Letter addressed to Whistleblower or an email sent to email@example.com
- Letter addressed to Privacy Officer or an email sent to firstname.lastname@example.org
You can remain anonymous
Fisher Leadership respects and protects your identity if you choose to make an anonymous report. You can choose to remain anonymous while making a report, interacting with case managers during an investigation of your report, as well as after your case is closed.
If you decide to disclose your identity, will we still work to protect your identity and will outline and document who in the organisation will know you submitted your report. We will also take all steps necessary (and outlined in this policy) to ensure you do not suffer any retaliation.
It is worth noting that Fisher Leadership will make every endeavour possible to investigate your report, but in some cases, there are limitations of what can be achieved if the informant decides to remain anonymous.
What is the investigative process?
When a report is received by the Whistleblower, Fisher Leadership’s Legal Counsel will do an initial assessment and confirm it is a valid report, and there is sufficient information to proceed to an investigation. Where a report is made the Privacy Officer, it will be conducted by the Privacy Officer.
Depending on the nature of the report made, use may be made of independent third parties to undertake any investigation, and could include HR consultants, accountants, or investigative firms as appropriate.
Upon completion of the investigation, a report will be prepared and submitted to the Managing Director or Chair of the Board as appropriate to the nature of the issue. Recommendations as to resolution or action will then be implemented by the Board.
What is the process of updating the person making the report?
As part of our investigative process, Fisher Leadership will update the person who made the report of the progress of the investigation. We will strive to provide as much feedback on the investigation as possible. However, due to privacy considerations, there is at times information that cannot be shared with the person who made the report.
How potential retaliation will be managed
A person making a report might be concerned that employees, associates, management, or the organisation might retaliate against them. In this case, Fisher Leadership will protect the informant from:
- Being terminated or having their employment ceased;
- Performance management;
- Harassment on the job or workplace bullying;
- Warnings or disciplinary actions;
- Any other action that can be perceived as retaliation for making a report.
How Fisher Leadership deals with retaliation
Fisher Leadership does not tolerate any attempts to retaliate against a person who has made a report. Any employee or associate that is found retaliating will face disciplinary action, including the potential to be terminated from their roles.
Separation of issues
Fisher Leadership will still be able to raise any issues related to work or performance related issues. While we will protect the person making the report from any retaliation, it is also important that team members are still effective in their job. Fisher Leadership can still raise any performance or contract issues with the informant, but they will be separated and not influenced at all from any reports that have been made.
Protection for others
Other parties that might have to bear witness or are involved in the investigation will be protected from retaliation in the same manner as the person making the report.
Legislative/regulation protection & assistance
If in any jurisdictions or locales where Fisher Leadership operates has whistleblowing protection laws that provide a higher level of protection than what is included in this policy, the local legislation will take precedence.
From time to time, Fisher Leaderships’ whistleblowing policy will need to change to align with our values, best practices, improvements, as well as legislation and regulations. Any changes to our whistleblowing policy will be communicated with all employees and any relevant stakeholders.
All changes in the policy will be approved by the Board of Directors.
Reporting to the Board of Directors
The Board of Directors is updated every quarter on the whistleblowing program, inclusive of reports, investigations, and results. Reports or investigations carrying an undue amount of risk will be reported to the Board of Directors outside of the quarterly updates.
|Code of Conduct Policy|
|Information Security Policy|
Governance – Policy Development and Review
Policy Name: Whistleblower Policy
Policy Owner: Chief Finance & Technology Officer
Issue Date: June 2020
Last Revised Date: 17/06/2020
Next Review Date: 17/06/2022