Whistle Blowing Policy
1. INTRODUCTION AND STATEMENT OF INTENT
As specified in the Code of Conduct, the Financial Policies & Procedures and the Anti-Fraud Policy, Valid Nutrition (VALID) will continuously strive to ensure that all its financial and administrative processes are carried out with integrity and reported honestly, accurately, transparently and in a spirit of full accountability and that all decisions are taken objectively and free from personal interest or conflict. VALID will not condone any behaviour that falls short of these principles.
While all employees (and volunteers) of Valid Nutrition are required to sign the Code of Conduct prior to commencing employment, all members of the organisation have a responsibility for ensuring these principles are put into practice and for reporting any breaches identified.
The objective of this policy is to record VALID’s commitment to providing a confidential and secure mechanism to enable VALID’s employees and other stakeholders to report concerns about behaviour that might be unsafe, unlawful, unethical, corrupt, irregular or otherwise contrary to VALID’s policies. This document defines the policy and outlines the procedures for “protected internal disclosures”, that is, “whistle blowing”.
This policy should be read and applied in conjunction with the prevailing VALID policies, codes and guidelines on related matters, including (but not limited to):
- Code of Conduct;
- Anti-Fraud Policy;
- Finance Policy & Procedures.
Use of the “whistle blowing” facility is available to all directors, employees, officers and authorised representatives (“Relevant Persons”) of VALID, as well as suppliers, customers, service providers, business collaborators and other stakeholders, and is designed to provide a legitimate means by which VALID can become aware of conduct that is, or may be, contrary to its declared Values, Policies and Principles. “Whistle blowing” provides a confidential means of conveying relevant information, however, it does not replace existing lines of communication.
4. RESPONSIBILITY AND ACCOUNTABILITY
The maintenance, revision and distribution of this policy is the responsibility of the CEO and is approved by VALID’s Board. VALID’s senior management are responsible for ensuring that the policy is effectively communicated and implemented throughout the organisation.
- 5.1 REPORTABLE ISSUES
Relevant Persons have a duty to report any conduct that is, or maybe, contrary to VALID’s published codes and policies. Ideally this should happen through normal lines of communication however, it is appreciated that in certain circumstances, this may be difficult and hence the rationale for this specific policy document.
- 5.2 WHISTLE BLOWER PROTECTION
The protection of whistle blowers, including keeping the identity of the individual confidential, is fundamental to achieving the objectives of this policy. The whistle blower must disclose the information in good faith, must reasonably believe that the information being disclosed is true and must not act for personal gain. In these circumstances, the whistle blower will ordinarily be protected from adverse consequences resulting from the disclosure. What this means is that VALID commits that the person will not, as a result of the disclosure, be:
- subjected to disciplinary action; • dismissed, suspended, demoted, harassed or intimated;
- transferred against his or her will or where relevant, refused an opportunity for transfer or promotion;
- subjected to a term or condition of employment or retirement which is altered to his or her detriment;
- refused a reference or provided with an adverse reference;
- threatened with any of the above;
- otherwise adversely affected in his or her employment for making the disclosure.
These commitments apply UNLESS the whistle blower is responsible for, or otherwise implicated in, any irregular conduct that is illegal or in breach of VALID policies or conditions of employment. VALID will have regard to the relevant applicable legislation of the country of operation in respect of the protection of informants.
- 5.3 REPORTING PROCEDURES
Any Relevant Person or other stakeholder who wishes to disclose information as contemplated in this policy, may do so in the following manner:
- By Email sent to: email@example.comIn making a disclosure using these means, the whistle blower is encouraged to provide as much information as possible relating to the matter. The more information that is available, the more thoroughly the matter may be investigated and, as a result, addressed or resolved.
- 5.4 FALSE REPORTING
Deliberate reporting of false information is a serious breach of this policy and considered an act of gross misconduct. Any such reporting shall subject the individual concerned to disciplinary action.
- 5.5 INVESTIGATIVE PROCESSThe process is as follows:
- VALID will appoint an individual responsible for receiving reports on disclosures communicated via the reporting facility as outlined in 5.3 above;
- The appointed individual will ensure that reports are provided to the CEO and management team in an appropriate and consistent format;
- The CEO will be responsible for identifying an appropriate response team, drawing on the internal expertise and experience, to complete the investigation as quickly as feasible;
- Depending on the nature of the disclosure, the response team may determine that the matter can be appropriately dealt with (a) internally or (b) externally, as the case may be and the CEO may appoint an external agency as appropriate.
- The appointed individual will be responsible for reporting on all disclosures relating to this policy in accordance with the agreed response framework as directed by the CEO. This will include communicating a final decision and outcome to the Whistle-blower.Reviewed: 1st December 2021
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