The St Vincent de Paul Society National Council of Australia Inc. (‘the Society’) has developed its Whistleblower Protection Policy as a key initiative to promote the Society’s culture of conducting its business with honesty, fairness and integrity. A breach of the Policy may, in some circumstances, result in disciplinary action up to and including dismissal. Any report of breaches under the Policy will be investigated.
The aim of the Policy is to:
- Reinforce the Society’s commitment to identifying and responding to concerns and fostering a culture of continuous improvement.
- Encourage the reporting of suspected or actual wrongdoing.
- Provide guidance on how to raise concerns and how those concerns will be investigated.
- Reassure anyone who raises a concern that they can do so without fear of retaliation, even if they turn out to be mistaken.
The Society encourages all staff to report wrongdoing; its attitude is - “when in doubt report”. All staff should feel confident and comfortable about reporting wrongdoing. The Society is committed to protecting the dignity, well-being, career and good name of anyone reporting wrongdoing. This includes providing the necessary support.
SCOPE AND APPLICATION
The Society encourages anyone with knowledge or reasonable suspicion of reportable conduct to report it as soon as possible. The Policy applies to all to help directors, employees, Society members, volunteers and contractors of the Society to identify any misconduct that may not be discovered unless there is a safe and secure means of disclosure. To the extent possible, it also applies to former employees.
WHO IS A WHISTLEBLOWER?
A whistleblower is defined as anyone who makes or attempts to make a report of reportable conduct under the Society’s Policy, consistent with the protection provided under the Corporations Act 2001.
WHAT IS REPORTABLE CONDUCT?
Reportable conduct is defined as any past, present or likely future activity, behaviour or state of affairs considered to be, but not limited to, dishonest, corrupt or fraudulent behaviour. A full list of reportable conduct is set out in the Society’s Policy. Reportable conduct usually relates to the conduct of the Society’s staff, but it can relate to the actions of a third party, such as a customer, supplier or service provider.
WHISTLEBLOWER PROTECTION OFFICER (WPO)
The Society has appointed the Chief Executive Officer as its Whistleblower Protection Officer (WPO), or in the case of a complaint against / notification involving the Chief Executive Officer, the National Council President. The WPO is authorised to provide certain protections where he/she deems appropriate for fulfilling their role. Anyone covered by the Society’s Policy can approach the WPO prior to, during, or after making a whistleblowing report to seek advice.
All reports must be made with a genuine and reasonable belief regarding the reportable conduct. Whistleblowers are requested to provide as much information as possible and any known details about the events underlying the report (e.g. date, time, location, name of person(s) involved, possible witnesses to the events, evidence of the events (e.g. documents, emails) and steps they may have already taken to report the matter elsewhere or to try resolve the concern). The Society’s Policy does not in any way restrict or diminish the right of any individual to make disclosures directly to relevant regulators.
Investigations of reportable conduct will be conducted in a manner that is confidential, fair and objective. Confidentiality extends to all information received from whistleblowers. All information will be held securely and in strict confidence. All reports received through whistleblowing channels are assigned to the nominated WPO who is responsible for conducting the investigation, and for keeping the whistleblower informed of the investigation’s progress in a timely way.
PROTECTION AND SUPPORT
Support and protection from personal or financial disadvantage applies to anyone making a report under the Policy, and extends to anyone else within the Society who is assisting the investigation, as well as to the WPO. The Society does not tolerate retaliation or adverse action related to a whistleblowing disclosure such as dismissal, harassment or discrimination toward anyone making a report.
A copy of the full Whistleblower Policy can be found here https://www.vinnies.org.au/icms_docs/321920_Whistleblower_Policy.pdf