Context and purpose
Sovereign is committed to maintaining an ethical work environment and an organisational culture where employees and others are encouraged to speak up about issues or conduct that concerns them. This could be anything from serious misconduct to noticing something which just doesn't feel quite right.
We encourage our employees and everyone who works with Sovereign to speak up where they see something wrong. As part of this, our Whistleblower Protection Policy (the policy) sets out how we will support people so they understand the process of making a disclosure and feel safe doing so.
What is a whistleblower?
For the purposes of the policy a 'whistleblower' is defined as a Sovereign director, manager, employee, former employee, temporary staff, volunteer, contractor, supplier or service provider of Sovereign, intermediary or auditor who makes, attempts to make, or wishes to make a disclosure about reportable conduct.
Reportable conduct is any conduct which is:
- Dishonest, fraudulent, corrupt, illegal or breaches of legislation
- A breach of internal policy
- Unethical or other serious or improper conduct
- Unsafe work practices
- Harmful to Sovereign's reputation or any other conduct which may cause financial or non-financial loss to Sovereign or be otherwise detrimental to the interests of Sovereign.
Making a disclosure
Disclosures of reportable conduct must be based on information that is directly known to the person making the disclosure. That person must have reasonable grounds to suspect the alleged conduct has occurred and be made in good faith.
A disclosure can be made to:
- Sovereign Manager or Manager Once Removed (employees only)
- Sovereign Human Resources Business Partner (employees only)
- External SpeakUP channel via the SpeakUP Hotline on 0800 444 198
- External SpeakUp channel via the AIA Ethics and Compliance website www.aiaethicsline.com
- Sovereign Head of Customer Risk & Compliance
- Sovereign Chief Risk Officer
The SpeakUP hotline is an independent, externally managed 24-hour phone line dedicated to reporting suspected or actual misconduct.
Disclosures to either the SpeakUP hotline or by the AIA Ethics and Compliance website may be made anonymously. If the whistleblower elects to remain anonymous when making the disclosure, they will be provided with a unique reference number. The whistleblower can continue to anonymously contact the SpeakUP hotline and quote this reference number to:
- provide further information regarding the disclosure; and/or
- express any concerns about their protection and request the Whistleblower Protection Officer's details.
Information received from the whistleblower will be treated strictly confidentially, and will not be shared unless:
- the whistleblower has been consulted and consented to the disclosure in writing; or
- we are compelled by law to do so.
Any breach of confidentiality in relation to the disclosure or whistleblower's identity will be taken seriously, and will be subject to investigation and potential disciplinary action.
Sovereign's process for managing disclosures of reportable conduct:
- Sovereign's Head of Customer Risk & Compliance manages disclosures of reportable conduct made via the SpeakUP hotline and the AIA Ethics and Compliance website.
- Disclosures warranting further investigation are referred to a Whistleblower Investigation Officer (WIO). The WIO conducts the investigation and updates the whistleblower of its progress.
- A Whistleblower Protection Officer (WPO) is informed of the investigation and acts to protect the whistleblower and their wellbeing.
- The WIO will inform the whistleblower of the outcome of the investigation. The allegation may be substantiated, not substantiated or not able to be substantiated.
- Any matters of a serious criminal nature will be reported to the Police or other appropriate regulatory authorities.
- In certain circumstances the whistleblower can escalate their disclosure to the Chief Risk Officer, or the Chair of the Board Audit and Risk Committee via the Company Secretary.
We will take all reasonable steps to protect a whistleblower from personal disadvantage as a direct result of making a disclosure, including protection from:
- unfair dismissal or demotion
- any form of harrassment
- current or future bias