All reports received by a Protected Disclosure Officer will be acknowledged within 3 business days.
Subject to the confidentiality requirements outlined in this Policy, all disclosures of Reportable Conduct made pursuant to this Policy will be referred to a Whistleblower Investigations Officer (WIO) to assist in the investigation of a report.
The WIO is Fiona McClelland, Senior Legal Counsel, reporting to the Chief Legal Officer & Company Secretary.
The WIO will assess the information provided and determine:
(a) whether the disclosure related to Reportable Conduct and qualifies for protection under this Policy;
(b) whether sufficient information exists to allow the report to be investigated, whether an investigation in required, and if so, determine the appropriate investigation process, including:
- the nature and scope of the investigation;
- who will conduct the investigation and whether that person should be external to Flybuys;
- the nature of any technical, financial or legal advice that may be required; and
- a timeframe for the investigation (having regard to the nature and scope of the Reportable Conduct, the complexity of the issues and any other relevant factors).
Flybuys may not be able to undertake an investigation in some circumstances, including if it is not able to contact the Whistleblower to obtain consent or information to enable an investigation to proceed.
The WIO will be in touch with the Whistleblower within 2 weeks of receiving a report from the Whistleblower and will advise of the next steps and timeframes where appropriate.
Where appropriate, Flybuys will provide initial feedback to the Whistleblower and keep them informed on a continuing basis regarding the investigation's progress and/or outcome (subject to considerations of the privacy of those against whom allegations are made). However, if the allegation is referred to the Police or other agency, this may not be possible.
The investigation will be conducted in an objective and fair manner, and otherwise as is reasonable and appropriate having regard to the nature of the Reportable Conduct and the circumstances.
The WIO will ensure that any employee mentioned in a Protected Disclosure is not unfairly treated during the course of the investigation of the matter. Employees will have the opportunity to be informed of and respond to any report of Reportable Conduct made against them.