The Whistleblower Policy establishes a comprehensive framework for encouraging employees to report suspected misconduct, unlawful conduct, fraud, corruption, health and safety risks, and other unethical behaviour without fear of retaliation. It outlines the Company's commitment to fostering a culture of integrity, transparency, and accountability while providing employees with protected reporting channels in accordance with the Protected Disclosures Act (PDA), the Labour Relations Act, and the South African Constitution. The policy further defines the types of misconduct that should be reported, the protections afforded to whistleblowers, circumstances where protection may not apply, reporting procedures, investigation processes, confidentiality requirements, and the Company's responsibilities in managing disclosures fairly, confidentially, and without victimisation.

What's Included

1. Introduction

• Purpose of the policy
• Ethical workplace culture
• Transparency and accountability
• Protection of whistleblowers
• Encouraging responsible reporting

2. Purpose

• Reporting workplace misconduct
• Internal reporting mechanisms
• Prevention of retaliation
• Early identification of unethical conduct

3. Legal Framework

• Protected Disclosures Act (PDA)
• Labour Relations Act
• South African Constitution
• Legal protection for whistleblowers
• Occupational detriment protections

4. Scope

• Employees covered
• Permanent, fixed-term and flexi fixed-term employees
• Management

5. Definition of Whistleblowing

• Protected disclosures
• Current and former employees
• Good faith reporting
• Types of reportable information

6. Misconduct That Should Be Reported

• Fraud and corruption
• Criminal conduct
• Sexual, physical and emotional abuse
• Health and safety risks
• Unfair discrimination
• Breaches of Company policies
• Improper conduct
• Attempts to conceal misconduct

7. Protection of Whistleblowers

• Protection against victimisation
• Protection against dismissal
• Confidentiality
• Good faith reporting requirements
• Occupational detriment protections
• Internal grievance rights
• CCMA and Labour Court recourse

8. Circumstances Where Protection Does Not Apply

• False or malicious disclosures
• Bad faith reporting
• Failure to follow reporting procedures
• External disclosures without reasonable cause

9. False Allegations

• Malicious reporting
• Abuse of the policy
• Criminal consequences
• Disciplinary action

10. Reporting Procedures

In-Person Reporting

• Internal reporting channels
• Confidential reporting
• Management responsibilities
• Identity protection

Anonymous Reporting

• Anonymous disclosure procedures
• Confidentiality safeguards
• Limitations of anonymous reporting
• Protection of whistleblower identity

Details Required When Reporting

• Incident descriptions
• Evidence and supporting information
• Persons involved
• Dates and sequence of events
• Good faith reporting requirements

11. Investigation Procedure

• Internal investigations
• Referral to external authorities
• Acknowledgement of disclosures
• Communication timeframes
• Progress updates
• Confidential investigation process
• Whistleblower representation
• Support during investigations