OBA Whistleblower Policy

1. Introduction

This policy document is version 1, written by Shane Appleyard and serves to act as a starting basis for future development via the OBA Governance Portal.

Overview of Whistleblower Policy: This Whistleblower Policy outlines Owned By All’s commitment to fostering a culture that encourages the reporting of any unethical, illegal, or unsafe practices within the organization. It is designed to provide clear guidelines for reporting, investigating, and addressing concerns raised by employees and stakeholders.

Importance of Encouraging Whistleblowing: Recognizing the importance of transparency and accountability, Owned By All understands that whistleblowing is a vital mechanism for uncovering and addressing misconduct. Encouraging whistleblowing promotes ethical behavior, safeguards the organization’s integrity, and contributes to a culture of trust and responsibility.

Commitment to Protecting Whistleblowers: Owned By All is committed to protecting individuals who come forward with genuine concerns. This policy reinforces our dedication to non-retaliation, confidentiality, and fairness throughout the whistleblowing process. Whistleblowers play a crucial role in upholding our values, and their protection is paramount.

2. Scope

Define the Scope of the Policy: This Whistleblower Policy applies to all employees, contractors, and stakeholders associated with Owned By All. It sets forth the framework for reporting and addressing concerns related to unethical, illegal, or unsafe practices within the organization.

Specify Applicability to All Employees and Stakeholders: The policy is applicable to every individual connected to Owned By All, irrespective of their position or role. All employees, contractors, and stakeholders are encouraged to use the whistleblowing mechanism if they become aware of any misconduct that may harm the organization’s integrity or violate its policies.

Clarify Types of Incidents Covered: Incidents covered by this policy include, but are not limited to, fraud, corruption, harassment, discrimination, safety violations, and any other activities that contravene legal, ethical, or organizational standards. The policy aims to provide a comprehensive framework for reporting a wide range of concerns.

3. Definition of Whistleblowing

Provide a Clear Definition of Whistleblowing: Whistleblowing is the act of reporting concerns, grievances, or information about suspected misconduct within Owned By All. It involves bringing attention to actions that may be illegal, unethical, or against organizational policies.

Distinguish Between Internal and External Whistleblowing: Internal whistleblowing refers to reporting concerns within the organizational structure, utilizing designated channels. External whistleblowing involves reporting concerns to external entities such as regulatory authorities or the media when internal channels are not viable or effective.

Emphasize the Importance of Reporting Wrongdoing: This policy underscores the critical role whistleblowing plays in maintaining the organization’s integrity and ethical standards. It encourages individuals to come forward without fear of retaliation, ensuring a culture of transparency and accountability.

4. Confidentiality and Anonymity

Outline Procedures for Maintaining Confidentiality: The policy establishes clear procedures to safeguard the confidentiality of whistleblowers. It emphasizes the responsible handling of information, limiting disclosure to those directly involved in the investigation or resolution process.

Specify Mechanisms for Anonymous Reporting: Recognizing the importance of anonymity in certain cases, the policy provides secure and confidential channels for whistleblowers to submit reports without revealing their identity. This ensures that individuals feel safe when reporting concerns.

Communicate Non-Retaliation Commitment: Owned By All is committed to protecting whistleblowers from retaliation. The policy explicitly communicates this commitment, assuring individuals that they will not face adverse consequences for reporting concerns in good faith.

5. Reporting Procedures

Establish Clear Reporting Channels: The policy ensures clarity in reporting procedures, delineating specific channels through which whistleblowers can submit their concerns. This transparency facilitates a smooth and efficient reporting process.

Provide Multiple Avenues for Reporting: Recognizing the diverse preferences and comfort levels of whistleblowers, the policy offers multiple reporting avenues such as hotlines, email, or other secure platforms. This ensures accessibility and encourages individuals to come forward.

Designate Responsible Parties for Receiving Reports: The policy designates responsible parties or individuals who are entrusted with receiving and managing reports. This helps streamline the reporting process and ensures that concerns are directed to the appropriate channels for investigation and resolution.

6. Investigation Process

Define the Process for Investigating Whistleblower Reports: The policy provides a well-defined process for investigating whistleblower reports, outlining the steps to be taken from the receipt of the report to the conclusion of the investigation. This clarity ensures a systematic and thorough examination of reported concerns.

Identify Investigative Authorities or Teams: To maintain objectivity and expertise in handling whistleblower reports, the policy identifies specific authorities or teams responsible for conducting investigations. This ensures that investigations are carried out by individuals with the requisite skills and independence.

Emphasize Impartiality and Fairness: Recognizing the importance of fair and unbiased investigations, the policy places a strong emphasis on impartiality. This commitment ensures that the investigative process is conducted without prejudice, promoting trust in the resolution of reported issues.

7. Protection Measures

Outline Protection Measures for Whistleblowers: The policy explicitly outlines a set of protection measures designed to safeguard whistleblowers. These measures may include confidentiality, anonymity, and other safeguards to shield individuals who come forward with concerns.

Communicate Non-Retaliation Policies: To foster a culture of openness, the policy communicates the organization’s commitment to non-retaliation. Whistleblowers are assured that they will be protected from any form of reprisal or adverse actions as a result of their disclosure.

Ensure Legal Protections Are Clearly Stated: Recognizing the legal implications, the policy clearly states the legal protections afforded to whistleblowers. By providing this information, the policy ensures that individuals are aware of their rights and the legal framework supporting their disclosures.

8. Disciplinary Actions

Specify Consequences for False Reporting: The policy establishes clear consequences for individuals found to be engaging in false reporting. This ensures that the whistleblowing process is not abused and discourages malicious or misleading disclosures.

Outline Disciplinary Actions for Wrongdoers: In addition to consequences for false reporting, the policy outlines disciplinary actions for individuals found to be engaged in wrongdoing. This emphasizes the organization’s commitment to addressing misconduct and maintaining integrity.

Emphasize Fairness in Handling Allegations: Throughout the disciplinary process, the policy places a strong emphasis on fairness. Procedures are designed to ensure a fair and impartial handling of allegations, respecting the rights of all parties involved.

9. Communication of Policy

Communicate the Whistleblower Policy to All Employees: The policy emphasizes the importance of widespread awareness. Regular communication ensures that all employees are informed about the existence and details of the Whistleblower Policy.

Provide Training on the Policy and Reporting Procedures: To enhance understanding, the organization offers training programs that cover the Whistleblower Policy and reporting procedures. This empowers employees to confidently and effectively use the whistleblower channels.

Regularly Reinforce Awareness of the Whistleblower Program: Ongoing efforts are made to reinforce awareness of the whistleblower program. This may include periodic reminders, updates, or campaigns to ensure that the policy remains well-known and accessible to all members of the organization.

10. Policy Review and Revision

Commit to Regular Review of the Whistleblower Policy: The organization commits to a systematic and periodic review of the Whistleblower Policy. This is essential for ensuring that the policy remains aligned with legal standards and organizational needs.

Describe Procedures for Policy Updates: Procedures are in place to facilitate updates to the Whistleblower Policy. This includes a structured process for reviewing, revising, and approving changes to the policy to address emerging needs or legal requirements.

Communicate Policy Revisions to Relevant Stakeholders: Any revisions to the Whistleblower Policy are promptly communicated to relevant stakeholders. This ensures that all members of the organization are aware of the latest policy updates, maintaining transparency and accountability.

11. Contacts

Designate Contacts for Whistleblower Concerns: The organization still needs to designate specific individuals or offices to serve as points of contact for whistleblowers. These contacts are knowledgeable about the Whistleblower Policy and can provide guidance to those seeking to report concerns.

Establish Reporting Channels for Whistleblower Issues: Reporting channels are clearly defined to facilitate the submission of whistleblower concerns. These channels may include a dedicated hotline, email address, or other secure means through which whistleblowers can safely and confidentially report their concerns.