Our commitment.
The purpose of the Speak Up Policy is to encourage and support all ME employees (both current and former), contractors, officers, suppliers, brokers and third parties (“ME people”) to report suspected or actual misconduct, as well as unlawful activity.
A person who reports this type of conduct, under the Speak Up Policy, is known as a whistleblower. A whistleblower may advise ME that they wish to remain anonymous.
ME is committed to supporting and protecting those who speak up, by providing a safe means to report wrongdoing, whilst effectively investigating and managing concerns.
What is reportable conduct?
ME People are encouraged to raise concerns regarding suspected or actual inappropriate conduct (defined as “Reportable Conduct” within this Policy). “Reportable Conduct” includes conduct that is or involves:
- Fraudulent
- Illegal
- Corrupt
- Bribery
- Dishonest
- Misleading
- Unethical
- Abuse of authority
- Wilful breaching of legislation
- Wilful breaching of internal policies
- Inappropriate conduct
- Questionable accounting or auditing
- Unsafe work practice and health risks
- Discriminating
- Bullying or harassment
- Non-adherence to ME’s values
- Victimisation
- Any other kind of serious impropriety
How to make a report.
There are several ways you can lodge a report:
1. Confidentially via ME’s Speak Up Online Reporting Tool supported by an external 3rd party
Note: This online reporting tool enables reports to be anonymous. It is administered by an external company who may make contact for further information, but will not pass on any information about you to ME.
If you wish to report anonymously, read the guidelines provided within the form, to ensure you remain anonymous.
2. Employees with access to ME’s incident management system can report a Confidential Incident or a Speak Up matter.
Note: This cannot be an anonymous report but as a Confidential Report access will be restricted to relevant senior staff (refer to No. 1 if you wish to remain anonymous).
3. Directly to any Manager or senior representatives from People Experience, Compliance or Legal
Protection and support.
ME must ensure there is appropriate protection for those who speak up. ME will protect people who speak up and will take all reasonable steps to protect the identity of the person who speaks up and ensure there is no retaliation or adverse action related to the disclosure. This includes protections against:
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Termination of employment
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Performance management
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Bullying, harassment or victimisation
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Civil or criminal liability.
ME has zero tolerance for retaliation against those who speak up. All reports of retaliation will be investigated in line with ME’s Conduct at Work Policy.
Protections may not be extended to a person who speaks up where they:
ME has a Speak Up Protection Officer who is tasked with ensuring the identity of ME person is respected and protected appropriately throughout the handling, investigation, and reporting of a speak up incident. This role must be performed by an individual who can carry out the required duties without a conflict of interest.
Investigation.
Once a report is received a preliminary review will be performed as soon as possible and ideally within one business day of it being raised. If it is decided the matters raised in the report should be investigated, ME will conduct an investigation. Unless the person lodging the report decided to remain anonymous, where appropriate, ME will keep them informed of the findings and final outcome.
Reporting and Governance.
After the initial review, the following should be documented:
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The ME person's status regarding anonymity;
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Whether an investigation is required, must be deferred to the relevant Committee;
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Where appropriate and able, the person who made the report may be informed of the findings but will not receive a copy of the report; and
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Substantiated material outcomes will be reported immediately to the relevant Committee and the Board (as appropriate). These reports will be made on a ‘no names’ basis, to maintain confidentiality.
Reports on the number and type of Speak Up reports will be provided to the relevant Committee and Board annually. The Speak Up Policy is reviewed regularly.
This policy is effective as of 31 October 2018.