Whistleblower Policy - PDF

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					Whistleblower Policy
1              Principles and Purpose

This Whistleblower Policy documents Chandler Macleod Limited’s commitment to maintaining
a working environment in which employees and internal contractors are able to report
suspected instances of unethical, unlawful or undesirable conduct without fear of intimidation
or reprisal.

The Whistleblower Policy is an integral part of the Corporate Governance program of
Chandler Macleod Limited.

The purpose of this Policy is to assist the Company in the detection and resolution of
unacceptable conduct and to protect those persons who raise issues of potential
unacceptable conduct.

2         Conduct Covered by this Policy

Unacceptable conduct covered by this Policy includes any conduct which potentially;

         Is dishonest, fraudulent or corrupt;
         Is criminal or breaches State or Federal Law;
         Is unethical within the meaning of the Company’s Code of Conduct or the RCSA Code
         of Conduct; or
         Involves substantial risk to health and safety of employees or the public, and

would, if proven, constitute either by the Company or its employees;

         An illegal act or omission;
         A criminal offence; or
         Reasonable grounds for dismissing or terminating the services of an employee that
         was engaged in the conduct.

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3          Application of Policy

This Policy applies to all employees, contractors and Directors of Chandler Macleod Limited
whether full time, part time or casual, of any level of seniority and employed or engaged as an
internal staff member of the Company.

4          Protection of Whistleblowers

4.1        Definition of Whistleblower

For the purpose of this Policy, a Whistleblower is any employee, Director or internal contractor
of Chandler Macleod Limited who, whether anonymously or otherwise discloses or attempts to
disclose allegedly unacceptable conduct in accordance with this Policy.

4.2         Protected Disclosure

A Whistleblower will be protected under this Policy from reprisal or repercussions from the
Company arising from the disclosure of alleged unacceptable conduct, provided that the
disclosure is:

      made in good faith;
      is based on reasonable grounds; and,
      the disclosure is made in accordance with clause 4.3 below.

4.3         Disclosing Information of Alleged Unacceptable Conduct

A Whistleblower should report the alleged unacceptable conduct to the Legal Counsel or the
Chairman of the Audit and Risk Management Committee.

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4.4         Investigation

Legal Counsel and the Chairman of the Audit and Risk Management Committee shall
consider what further action, if any, is to be taken.

4.5         Contact Details

Legal Counsel can be contacted by telephone on (02) 8913 7713 or email at

The Chairman of the Audit and Risk Management Committee can be contacted by telephone
on 02 8913 7807 or email at chairauditcommittee@chandlermacleod.com.

5          Protecting the Whistleblower

Chandler Macleod is committed to the protection of Whistleblowers against action taken in
reprisal for making protected disclosures.

The Whistleblower will not be protected under this Policy if:

      They are involved in the unacceptable conduct, to the extent of the reasonable
      consequences flowing from their involvement, although an admission may be a
      mitigating factor when considering disciplinary or other action.

      The Whistleblower makes a knowingly false report regarding alleged unacceptable
      conduct. The giving of the knowingly false report will be considered a serious matter
      and render the person concerned subject to disciplinary proceedings including
      termination of employment.

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      They disclose the information regarding the allegation of unacceptable conduct to
      anyone other than Legal Counsel or the Chairman of the Audit and Risk Management
      Committee, except where required to disclose the information by law.

6          Confidentiality

6.1         Protect Confidentiality of Identity of Whistleblower

Chandler Macleod will use all reasonable efforts to protect the identity of the Whistleblower.

6.2         Disclosure in Certain Circumstances

Chandler Macleod reserves the right however, to disclose:

      the identity of the Whistleblower;
      the information disclosed by the Whistleblower; and/or,
      information that may lead to the identification of the Whistleblower,


      The Whistleblower has given their consent to the disclosure;
      The disclosure is required by law;
      The alleged unacceptable conduct relates to a contravention or possible contravention of
      the Corporations legislation (by reporting the alleged unacceptable conduct the
      Whistleblower is deemed to have given consent to the disclosure within the meaning of
      Section 1317AE of the Corporations Act 2001 (as amended);
      The disclosure is necessary to prevent or lessen a serious threat to a person’s health
      and safety; or
      It is necessary to protect or enforce legal rights or interest or to defend any claims.

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6.3         Storage of Records and Access

Chandler Macleod will ensure that all records relating to a report about unacceptable conduct
are stored securely.

7          Privacy

Information disclosed regarding personal or sensitive information within the meaning of the
Privacy Act will be treated in accordance with the Company’s Privacy Policy subject to access

      Legal Counsel;
      External Auditors;
      Directors of the Company.

8          Reporting to the Audit and Risk Management Committee

At each meeting of the Audit and Risk Management Committee of the Board the Legal
Counsel and or the Chairman of the Audit and Risk Management Committee shall provide a
report summarising activities under this Policy, but without the identity of the Whistleblower
unless required under clause 6.2.

9          Reporting Outside of Chandler Macleod Limited

The purpose of this Policy is to allow employees and internal contractors an avenue for the
reporting of matters of concern regarding the Company within the internal structures of the

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All employees and internal contractors are required to maintain their duties of confidentiality
regarding Company information and specifically their obligation not to disclose confidential
information of the Company to persons outside of the Company.

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