Whistleblowing
1. Overview
This policy aims to inform and direct any person to report evidence of malpractices and allegations of misconduct in a confidential manner. It allows any person to raise concerns they feel unable to direct to their line manager or through our Contact Us facility on our website and to report them in a confidential or anonymous manner without fear of retaliation and in the knowledge that it will be taken seriously and investigated.
2. Scope
This policy is for any person working with or for World Vision SA, this includes; - employees, consultants, contractors, partners, volunteers, interns, trustees. Additionally, this policy is available as a reporting mechanism to all beneficiaries, donors, sponsors, visitors, contractors and partners of WVSA. It encourages disclosures to be made in the public interest without restriction or repercussion.
3. Definitions
Misconduct – conduct that constitutes a criminal offence, failure to comply with legal and regulatory obligations, miscarriage of justice, health and safety danger, environmental risk or a concealment of any of these. Failure to comply with a WVSA policy or breaches of the WVSA Code of Conduct or Behavioural Protocols may also constitute misconduct.
4. Cross References
Confidentiality and Data privacy will be maintained in accordance with POPI Act 2013.
5. Policy
This policy is intended to address matters of a serious nature relating to misconduct by WVSA or its employees and associates. WVSA provides and promotes the Integrity and Protection Hotline operated by a third-party vendor with multilingual support, for anyone to access by email or phone twenty-four hours of the day, as the mechanism to use for reporting any allegations of misconduct. An allegation must be made in good faith and not from personal motives. All allegations will be rigorously investigated. WVSA will take appropriate action where claims of unlawful or unethical behaviour are substantiated. Confidentiality with respect to the identity of the Whistleblower and the information revealed will be maintained as is fully practicable, but subject to overriding legal requirements. WVSA gives its assurance that no whistleblower who makes a bona fide report under this Policy will be subjected to any detriment by WVSA as a result.
5.1 Allegations covered;-
- Dishonesty, fraud or corruption;
- Instances of bribery or suspected terrorist engagement or involvement;
- Illegal acts (e.g. theft, drug sale or use, violence, harassment, criminal damage to property or other breaches of law);
- Unethical actions (e.g. dishonestly altering company records, engaging in questionable accounting practices or wilfully breaching the organisation’s Code of Conduct or Ethical Policy);
- Actions that are potentially damaging to the organisation or dangerous to individuals connected with it (e.g. unsafe work practices, substantial wasting of resources);
- Actions likely to cause financial loss or damage to the reputation or be otherwise detrimental to organisational interests;
- Any other kind of serious impropriety.
To report an allegation by phone or online, you should visit the website www.worldvision.ethicspoint.com or phone 0800992604.
An allegation should contain as much information as possible; - the name of persons involved, dates, times, locations, facts relevant to urgency, documentation, witnesses and any supporting evidence.
5.2 Investigation; - all allegations of misconduct will be promptly acknowledged and recorded by the independent third party. This will generate an electronic report which will be received by WVSA’s Safeguarding Manager and Director of People & Culture. Allegations will be consistently and fairly investigated. The Director of People & Culture will appoint an appropriate individual to undertake the investigation. Any individual who has been implicated will be informed, as appropriate, of the investigation and given the opportunity to provide evidence. All investigations will be confidentially documented and shared as appropriate with WVSA Senior Leadership and Directors, so that the necessary corrective action can be taken. Upon conclusion of the investigation the reporter will be informed that the process has been followed and completed. Should the matter concern the Director of People & Culture it should be directly reported to a Director whose contact details can be obtained from the Governance Manager by e-mail, joyce_khosa@wvi.org.
5.3 Allegations of misconduct: - matters of discrimination, bullying or harassment, perceived unfair treatment by an employee, complaints about the work environment, issues concerning pay or benefits. These will be handled by the Grievance or Dignity at work policies and should be referred to the People & Culture department. Only if a person does not believe these allegations have been fully investigated should they then be submitted through the Whistleblowing procedure
5.4 Training & Awareness: - all employees will receive information and training that will inform and direct them to this policy and how to access the Integrity and Protection Hotline. External partners, contractors, consultants, supporters and beneficiaries can access this via our website.
6. Non-compliance
Appropriate disciplinary action will be taken against any employee who violates this policy e.g. by violating a whistle-blower’s anonymity or engaging in retaliation against a whistle-blower or where a disclosure was made in bad faith.
If it should become clear that the procedure has not been invoked in good faith, for example for malicious reasons or to pursue a personal grudge against another person, this will constitute misconduct and will be dealt with in accordance with the terms of WVSA’s Disciplinary Policy.
7. Reporting and Monitoring
The investigation report will contain a clear description of the alleged incident or issues, corrective action already taken or advised, an assessment of potential risk to the organisation and proposed mitigation, a conclusion and further implications or reporting to statutory authorities.
Where it is believed that a “Serious Incident”, may have taken place the matter will be escalated according to WVSA’s Serious Incident Reporting policy.
Confidentiality with respect to the identity of the whistle-blower, the information revealed, and all evidence supplied will be maintained fully practicable within the parameters of the POPI Act 2013.
The number of whistleblowing cases will be reported by the Director of People & Culture to the Board.