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This page explains how to read this policy and describes its purpose.
The purpose of this policy is to encourage reporting of wrongdoing that is of legitimate concern by providing a convenient and safe reporting mechanism, and protection for people who make serious wrongdoing disclosures.
The purpose of this policy is to provide information on:
This policy applies to Whistleblowers, who can be current or former employees as well as others with a connection to the Wisdom Group such as contractors, suppliers, brokers and auditors or a relative or dependant of these individuals or their spouse. This policy also applies to the Wisdom Group Directors.
This policy applies to all companies in the Wisdom Group of companies, including; Wisdom Properties Group Pty Ltd, Wisdom Constructions Pty Ltd and Wisdom Landscapes Pty Ltd.
This policy will be made available on the Wisdom Group’s intranet website.
3. Policy Statement
At Wisdom Properties Group (the Company) our Code of Conduct emphasises the importance of speaking up as a critical component of our values expectations. We are committed to fostering a culture where you feel safe to speak up on matters that concern you.
4. Matters That Should be Reported
Any matter that an individual has reasonable grounds to believe is misconduct or an improper state of affairs or circumstances, or is in breach of Company policies or in breach of the law should be reported in accordance with this Policy.
Reportable matters include any conduct that involves:
4.1. Other Complaint Mechanisms
This policy is in addition to:
An exception to this is where the issue is wrongdoing of a serious nature, yet the existing reporting system failed to attend to the issue or has processed it in a substantially inappropriate, grossly unfair or heavily biased manner.
5. Making a Report
There are three reporting avenues available to those who are eligible to make a disclosure. The first option is to make a disclosure to the General Manager or Wisdom Properties Group.
Where a Whistleblower is reluctant to make a report to Wisdom directly, additional reporting avenues are available.
Reporting avenues are:
Sumitomo Forestry Australia
Sumitomo Forestry Australia
Suite 7, 395 Ferntree Gully Rd, Waverley VIC 3149
The Company encourages the reporting of any instances of suspected unethical, illegal, fraudulent or undesirable conduct involving the Wisdom Group of companies. The Company provides protections and measures so that those persons who make a report may do so confidentially and without fear of intimidation, disadvantage or reprisal
When a person makes a disclosure:
The Company respects and protects your identity if you choose to make an anonymous report.
The Company will not disclose a Whistleblower’s identity unless:
When a report is investigated it may be necessary to reveal its substance to people such as other Wisdom Properties Group personnel, external persons involved in the investigation process and, in appropriate circumstances, law enforcement agencies.
It will be necessary to disclose the facts and substance of a report to a person who may be the subject of the report as it is essential for natural justice to prevail. Although confidentiality is maintained, in some circumstances, the source of the reported issue may be obvious to a person who is the subject of a report.
Certain senior managers might be alerted to the report as part of the reporting process or if they are involved in the investigation in some manner. Any information that could potentially identify an anonymous informant will be held in the strictest confidence and will not be shared, unless the Company is compelled by law.
Wisdom Properties Group will take reasonable precautions to store any records relating to a report of wrongdoing securely and to restrict access to authorised persons only.
If you decide to disclose your identity, the Company will work to protect your identity and will outline and document who in the organisation will know you submitted your report. The Company will also take all steps necessary to ensure you do not suffer any retaliation.
It is worth noting that the Company will make every endeavour possible to investigate your report, but in some cases, there are limitations of what can be achieved if the informant decides to remain anonymous.
Wisdom Properties Group will not tolerate any retaliatory action or threats of retaliatory action against a Whistleblower, or against a Whistleblower’s colleagues, employer (if a contractor, consultant or supplier) or relatives.
Any such retaliatory action or victimisation in reprisal for a disclosure made under this policy will be treated as serious misconduct and will result in disciplinary action, which may include dismissal. In some circumstance it may be illegal; in which Wisdom Properties Group will notify Police.
The Company will also protect the informant, if they are an employee, from adverse action as a result of making a complaint.
6. The Investigation Process
All Whistleblower submissions will be reported to the Managing Director, Sumitomo Australia upon receipt.
Sumitomo Forestry Managing Director will, in conjunction with Wisdom Properties Group, investigate all matters reported under this policy as soon as practicable after the matter has been reported.
The Investigator (Company Representative) is appointed by the Managing Director, Sumitomo Forestry Australia, in conjunction with the General Manger of Wisdom Properties Group, and may be internal or external to Wisdom Properties Group. If the Investigator is internal, then the Investigator must have internal independence of line management in the area affected by the wrongdoing disclosure.
The investigation will be conducted in an objective and fair manner, and as is reasonable and appropriate having regard to the nature of the disclosure and the circumstances. Where a report is submitted anonymously, Wisdom Properties Group will conduct the investigation and its enquiries based on the information provided to it. However, anonymity can sometimes prevent Wisdom Properties Group from taking the issue further if Wisdom Properties Group is not able to obtain further information from the source of the report.
It is important for the Company to be transparent with our employees and outline what is the process for us to investigate a report submitted through our whistleblowing channels. Below, we have provided the different steps a company representative will go through once a report is received until the case is closed.
6.1. Disclosure Management
Wisdom Properties Group recognises that individuals against whom a report is made must also be supported during the handling and investigation of the wrongdoing report.
Wisdom Properties Group takes reasonable steps to treat fairly any person who is the subject of a report, particularly during the assessment and investigation process.
Where a person is identified as being suspected of possible wrongdoing, but preliminary inquiries determines that the suspicion is baseless or unfounded and that no formal investigation is warranted, then the Whistleblower will be informed of this outcome and the matter laid to rest.
The Managing Director of Sumitomo Forestry Australia will decide whether or not the person named in the allegation should be informed that a suspicion was raised and found to be baseless upon preliminary review. This decision will be based on a desire to preserve the integrity of a person so named, so as to enable workplace harmony to continue unfettered and to protect the Whistleblower where it is a bona fide disclosure.
Where an investigation does not substantiate the report, the fact that the investigation has been carried out, the results of the investigation and the identity of the person who is the subject of the report must be handled confidentially. Generally, where an investigation is conducted and the Investigator believes there may be a case for an individual to respond, the Investigator must ensure that a person who is the subject of a disclosure:
Where adverse conclusions are made in an Investigator’s report about an individual, that individual has a right to respond to those conclusions prior to any action being taken by the Company against them.
7. Breach of Policy
Breach of this policy may be regarded as misconduct, which may lead to disciplinary action (including termination of employment or engagement). An individual may also be exposed to criminal or civil liability for a breach of relevant legislation.
8. Related Policies
Other organisational policies that should be read in conjunction with this policy are:
Please direct all requests to Wisdom Homes by email at PeopleCulture@wisdomhomes.com.au or by mail to the following address:
Attention of the Privacy Officer Wisdom Properties Group Pty Ltd 17-19 Central Hills Drive Gregory Hills, 2557, NSW.