Whistleblower Policy
August 2023
Purpose
To encourage reports of Reportable Conduct and to provide confidence that raising a confidential or anonymous concern about Reportable Conduct will be addressed in an objective, confidential and independent manner that supports and protects individuals from reprisal or disadvantage.
NorthWestern Roads and each of its related entities (NWR) aims to act with integrity, in an ethical manner and has zero tolerance for non-compliance with the governance requirements outlined in this policy and the accompanying procedure.
This Policy is a very important tool for helping NWR to identify Reportable Conduct that may not be uncovered unless there is a safe and secure means for disclosing Reportable Conduct.
Scope
The Policy is a high-level overview of NWR’s approach to receiving reports of Reportable Conduct. It is not intended to be a complete guide and should be read in conjunction with NWR’s Whistleblower Procedure which outlines in greater detail the mechanisms and protections in place for all current and former Directors, Senior Executives, staff, officers of NWRG, contractors (including subcontractors), consultants, business partners or suppliers of goods or services and their staff, and third parties including intermediaries and associates (including relatives) in order to support a culture of compliance, honesty and ethical behaviour.
Capitalised terms in this Policy have the meaning given to them in the Whistleblower Procedure unless stated otherwise.
Reportable conduct
NWR strongly encourages anyone who has witnessed, or knows about, any Reportable Conduct or suspected Reportable Conduct, to report this immediately.
Reportable Conduct is any suspected misconduct or what the Whistleblower Laws call “an improper state of affairs or circumstances”. The Reportable Conduct needs to be in relation to NWR. To be protected, the Discloser does not need to have proof of the Reportable Conduct, but they do need to have reasonable grounds for their suspicion.
Examples include:
- breach of any law, including Commonwealth Laws;
- conduct that represents a danger to the public or the financial system, or that poses a serious risk to health and safety or the environment;
- criminal conduct (including in relation to theft, illicit drugs, violence or criminal damage to property);
- fraudulent or dishonest behaviour or which is a substantial or persistent waste of company resources;
- unethical or negligent conduct (including any breach of NWR’s Code of Conduct or generally);
- conduct that would constitute modern slavery or exploitation of vulnerable workers;
- victimising or threatening someone in connection with actual, potential or suspected whistleblowing;
- misconduct or an improper state of affairs or circumstances in relation to NWR’s tax arrangements; or
- conduct which is likely to cause financial or non-financial loss to or is otherwise detrimental to the interests of NWR.
Reportable Conduct can also be any of these activities involving third parties where the conduct could have significant implications for NWR.
Reportable Conduct can be reported:
- internally to an Eligible Recipient;
- to NWR’s external whistleblower service provider – KPMG Fair Call; or
- to an external authority or entity (e.g. ARIC or APRA).
In addition to this Policy, individuals who disclose Reportable Conduct may also have protections under the Corporations Act 2001 (Cth).
Investigations
Investigations will be conducted in accordance with the process set out in the Whistleblower Procedure.
Confidentiality
A Discloser may elect to remain anonymous when reporting Reportable Conduct. In these circumstances, a Discloser can refuse to answer questions that they feel may reveal their identity, but a Discloser should also assist attempts to set up an ongoing two-way communication with NWR. If a Discloser does not provide their name or contact details, NWR may not be able to fully investigate the matter or provide the individual with an outcome.
Supporting documents and processes
This Policy is supported by procedures and processes, including:
- who reports can be made to;
- how reports are investigated;
- action to be taken from reports;
- communication with the person making the report;
- protections and support afforded to Discloser; and
- addressing false reporting.
This Policy should be read in conjunction with NWR’s Whistleblower Procedure and the Code of Conduct Policy.
The Whistleblower Procedure and the Code of Conduct Policy is accessible on the intranet for current employees.
For other stakeholders, please contact NWR Group Manager Risk & Quality:
Email: NWR Reception reception@nwroads.com.au (marked highly confidential)
Phone: (02) 9834 9200
Monitoring
This Policy is supported by the Whistleblower Procedure which addresses all items within this policy and is supported with appropriate training to address obligations and processes for both NWR and personnel covered by the documents. Adherence to the requirements outlined in this policy is very important and breaches may result in disciplinary action up to termination of employment for employees.
How do we secure your information?
We implement safeguards and security measures to protect personal information we hold about you from risks such as misuse, interference, unauthorised access, modification or disclosure. We use a number of physical and electronic measures to protect your information as well as training our staff (and contractors) in our internal procedures and systems with respect to the handling of personal information. We also take steps to conduct checks on our third-party providers.
Phone (toll free): 1800 500 965
Mail:
The FairCall Manager,
KPMG Forensic,
PO Box H67,
Australia Square,
Sydney NSW 1213
Fax: +61 2 9335 7466
Contact Us
If you have any questions or comments about the Policy, or concerns or complaints, please feel free to contact us for NorthConnex by emailing us here.
