Treatment of Reports of Wrongdoing
Reports of wrongdoing will be reviewed as soon as possible by the Chair of the Risk Management Committee with the assistance of the Director of Finance and Operations. The Chair may utilize the assistance and direction of the Risk Management Committee and whomever it thinks appropriate. To avoid conflicts of interest this Policy generally excludes supervisors, line managers and senior managers, other than the Director of Finance and Operations, from the assessment and investigation of any disclosure. Appropriate investigation will occur dependent on the severity of the incident reported.
The principles of natural justice and procedural fairness apply to investigations into disclosures of wrongdoing. Thus, the person who is the subject of the disclosure is entitled to know at the assessment phase of an investigation the allegations made against them, and given the right to respond and put forward further material that may inform the outcome of the investigation. Knowing the identity of the person who made the allegation is not a part of natural justice, and should not be shared.
Each incident will be assessed according to its validity, significance and risk to the organization, and ability to be proven. Following an investigation, the report of the Designated Officer will include whether the disclosure was substantiated and, where appropriate, a recommendation for corrective action will be made. The results will be communicated to the witness, if a name was provided, and to the Board of Directors. If a disclosure of wrongdoing was not substantiated some recommendations for corrective actions such as improvements to the internal operations or disciplinary action may still be required.