Whistleblowing Policy

 Aim 

The Whistleblowing Policy is designed to provide guidance to all those who work with or within the organisation who may from time to time feel that they need to raise certain issues relating to the organisation with someone in confidence. Redwood recognises that effective and honest communication is essential if concerns about breaches or failures are to be dealt with effectively and the organisation’s success ensured. 

Purpose 

To encourage and enable a free and open culture for employees and others to raise serious concerns internally so that Redwood can address and correct inappropriate conduct and actions. It is the responsibility of all board members, employees, representatives, agents and/or contractors to report concerns about violations of Redwood’s Code of Conduct or Policies or suspected violations of law or regulations that govern Redwood’s operations. 

Policy Guidelines

This policy applies in cases where an employee genuinely believes that one of the following sets of circumstances is occurring, has occurred or may occur within the organisation, and that it is in the public interest for the employee to disclose it. The matters that may be disclosed in this way are:

• The committal of a criminal offence.
• A failure to comply with any legal obligation.
• A miscarriage of justice.
• A breach of health and safety rules, causing danger to any individual.
• Damage to the environment.
• Concealment of information tending to show any matter falling within any once of the preceding paragraphs.

There is no need for an employee to prove that the breach or failure that they are alleging has occurred or is likely to occur; a reasonable suspicion will suffice. i.e., where the employee reasonably believes that the information disclosed is substantially true. Employees should, however, note that they are not entitled to make a disclosure if in so doing they commit a criminal offence.

An employee who makes a disclosure is protected from detrimental treatment by the organisation, by a co-worker or by an agent of the organisation. Redwood is vicariously liable for the detrimental treatment. If this occurs, it should be raised immediately with the line manager so that the matter can be investigated thoroughly without undue delay. Detrimental treatment includes, for example, harassment and bullying or not complying with a person’s rights and entitlements under their contract of employment.

An employee is also protected from dismissal by Redwood for making a protected disclosure.

Employees who in the public interest raise genuine concerns under this policy will not under any circumstances be subjected to any form of detriment or disadvantage as a result of having raised their concerns.

Reporting Procedure

Redwood has an open-door policy, and suggests that employees share their questions, concerns, suggestions or complaints with their line Manager. However, if an employee is not comfortable speaking with their line manager, or they are not satisfied with the response, they are encouraged to speak with the relevant Executive Leader. If complaints received are in relation to suspected ethical and legal violations, the Executive Leader is required to report these in writing to Redwood’s General Counsel and Secretary of the Board, who has the responsibility to investigate all reported complaints.

Employees with concerns or complaints may also submit their concerns in writing directly to their line manager, the relevant Executive Leader, or General Counsel and Secretary of the Board.

Handling of Reported Violations

Managers who receive complaints from employees are required to promptly report these to the Whistleblowing Committee. The manager should check with the employee if they should do so anonymously or not and respect that choice. Redwood’s Whistleblowing Committee will notify the person who submitted a complaint (this can be the manager who reported the anonymous complaint) and acknowledge receipt of the reported violation or suspected violation. All reports will be investigated promptly, and appropriate corrective action will betaken if warranted by the investigation. The outcome of such investigation will be communicated back to the reporter of the complaint. Please send your complaint or any question regarding this policy to: [email protected].

Whistleblowing Committee

The General Counsel and Secretary of the Board is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The General Counsel and Secretary of the Board heads the Whistleblowing Committee, in which the complaints are discussed to ensure independent decisions and a four-eyes principle. In severe cases the Whistleblowing Committee may decide to use external resources to investigate complaints. After thorough investigation, the General Counsel and Secretary of the Board will report the findings back to the individual who reported it (in case this person is known). The Compliance Officer will also advise the Executive team of all complaints and their resolution and will report at least annually to the Corporate Controller on compliance activity relating to accounting or alleged financial improprieties.

Accounting and Auditing Matters

The General Counsel and Secretary of the Board shall immediately notify the Chief Operating and Financial Officer of any concerns or complaints regarding corporate accounting practices, internal controls or auditing and work with the Whistleblowing Committee until the matter is resolved. Acting in good faith, anyone filing a written complaint concerning a violation or suspected violation must have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Additional Information

Employees should be aware that the policy will apply where they reasonably believe that the information disclosed, and any allegation contained in it are substantially true. If any disclosure concerns information which the worker does not substantially believe is true, or indeed if the disclosure is made for personal gain, then such a disclosure will constitute a disciplinary offence for the purposes of the organisation’s disciplinary policy and procedures and may constitute gross misconduct for which summary dismissal is the sanction.

While Redwood hopes that such disclosures will never be necessary, it also recognises that circumstances may arise with which the organisation is unfamiliar. Each case will be treated on its own facts.