Whistleblowing means to flag, in the public interest, a danger, risk, wrongdoing or malpractice which affects yourself or others and that is incompatible with the values of the Manager. Even when these matters appear minor, they can be symptomatic of more serious concerns which could impair the reputational standing of the Manager and have a detrimental impact on the Manager culture.
The Manager is committed to a strong business performance and culture which reflects its corporate values and will carefully review and evaluate any reported concerns.
The aims of this policy are to:
1. Encourage employees, services providers and associates to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously, investigated appropriately and their confidentiality will be respected.
2. To provide guidance as to how to raise those concerns.
3. To reassure employees, services providers and associates that they should be able to raise genuine concerns without fear of reprisals.
WHAT TO REPORT
Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work.
This may include the following:
- failure to comply with any legal or professional obligation and/or regulatory requirements
- danger to health and safety
- damage to the environment
- bribery and corruption
- financial fraud or mismanagement
- breach of the Lendlease Values, Code of Conduct and internal policies and procedures
- conduct likely to damage our reputation
- unauthorised disclosure of confidential information
- deliberate concealment of any of the above matters
This list is not exhaustive.
WHO SHOULD REPORT
A whistleblower is a person who raises a genuine concern relating to any of the above. If you have any genuine concerns related to suspected wrongdoing or danger affecting any of our activities, you should report it under this policy.
This policy should not be used for complaints relating to your own personal circumstances.
Confidentiality and protection of the person making a report is a key basis of this standard. The best way to raise a concern is to do so openly through the channels described below. Providing as much information as possible to support your concerns allows the Manager to quickly form a view on next steps. It also allows the Manager to be able to provide feedback to you with regard to the outcome of the investigation. Raising a concern anonymously may limit the action that the Manager is able to take - proper investigation may be more difficult or limited if we cannot obtain further information from you and we will not be able to provide you with feedback.
To facilitate reporting with the assurance that reports made will be managed objectively, we have engaged the Chairperson of Audit & Risk Committee and General Counsel, Asia to provide independent Online reporting channel. The Online reporting channel facilitate the reporting of possible illegal, unethical, or improper conduct when the normal channels of communication have proven ineffective or difficult. They are available for use by all employees and outside parties, such as suppliers, contractors, tenants and other stakeholders, to report any concern regarding irregularities or questionable behaviour of employee, service provider or associate.
Particulars of the Online reporting channel are:
DEALING WITH REPORTS
Your report will be received and reviewed by the Chairman of Audit & Risk Committee (the “ARC”) who will determine the appropriate initial action. Reports are provided to relevant parties in the Manager at the level of Senior Management and to the Audit & Risk Committee (the “ARC”), unless the whistleblowing report is related to the Senior Manager directly.
Confidentiality around the identity of the reporter is maintained at all times, regardless of whether the report was made openly or anonymously. Your identity will only be revealed if you agree to allow this.
The Manager will not tolerate any retaliation towards employees who report concerns and any employees taking action in response to a report will be subject to the disciplinary procedure.
Upon receipt of the report, the ARC may:
- Determine whether circumstances warrant an investigation or review, by considering factors including, but not limited to, the severity of issue raised, credibility of the information and likelihood of confirming the information from attributable sources;
- Instruct the relevant management to conduct further investigations or review and take such remedial action as it deems appropriate;
- Review and investigate the report and ensure that there is no conflict of interests on the part of any person involved in the investigations;
- Engage such third parties as the ARC may determine, to take remedial, to commence or conduct further investigations or review, as deem appropriate;
- Report the matter to the authorities if deemed necessary upon consultation with legal counsel;
- Take any other action as the ARC may determine in the best interest of the Manager;
- Inform whistleblower of the likely timeline for a final response;
- Recommend any remedial or legal action to be taken, where necessary; and/or
- Notify whistleblower of actions taken or reasons should it be decided that no action is to be taken.
MAINTAINING THIS POLICY
The Manager and the ARC are responsible for ensuring the maintenance, regular review and updating of this policy. Revisions, amendments and alterations to this policy can only be implemented with approval by the ARC and the Board of Directors.