a) Any person who has reasonable grounds to suspect that reportable conduct as defined above (see heading “REPORTABLE CONDUCT”), or a breach of a law or other standard of behaviour has occurred, is encouraged to report that suspicion to the SVP of Access Devices or the Senior Human Resources Manager. If this is considered inappropriate, or if the person is concerned about seeking the protections given under this policy, he or she should raise the concern with NetComm’s appointed internal or external third-party contact by phone, or email, or in writing using the details below.
b) Please note that a Whistleblower should not make a disclosure to their line manager (unless they are the SVP of Access Devices, the Senior Human Resources Manager or the Legal Counsel), as this would result in not qualifying for protection as a Whistleblower under the Corporations Act.
Any items of concern may also be raised with NetComm’s Legal Counsel as follows:
i. Calls will be received by KMPG FairCall on recognised business days between 7 am and 5 pm (AEST).
ii. Outside these times, the Whistleblower may leave a voicemail or choose to have their call received by KPMG South Africa. If a voicemail is left with sufficient details, KPMG Australia will return the call upon resumption of the hotline’s normal business hours, as set out above. Calls are not recorded. The operators taking the call on this hotline are not associated with NetComm. They are trained, and experienced specialists dedicated to dealing with Whistleblowers and their concerns. Whistleblowers will be provided with a confidential reference number by the FairCall operator.
iii. The FairCall operator will prepare a FairCall report which details the misconduct as reported by the Whistleblower. All FairCall reports will be forwarded to an appropriate senior executive, Whistleblower disclosure review committee for action or referred to NetComm’s Legal Counsel.
iv. Please note that anonymous disclosures are still protected under the Corporations Act.
v. KPMG Privacy Statement - This service is provided by KPMG Australia. This service is an independently monitored, external, anonymous service for Whistleblowers to report concerns of possible fraudulent or unethical behaviour relating to NetComm. Where KPMG Australia collects personal information as part of this service, it is provided in accordance with KPMG Australia’s Privacy Statement: www.kpmg.com/AU/faircallprivacy
c) All disclosures should provide specific, adequate and pertinent information with respect to, among other things, dates, places, persons, witnesses, amounts, and other relevant information, in order to allow for a reasonable investigation to be concluded.
d) If the Whistleblower discloses his or her name in the disclosure, the person receiving the disclosure will acknowledge having received the disclosure and may initiate a follow-up meeting. However, if the disclosure is submitted on an anonymous basis, there will be no follow-up meeting regarding the disclosure and NetComm will be unable to communicate with the Whistleblower if more information is required, or if the matter is to be referred to external parties for further investigation.
e) All disclosures received will be dealt with on a confidential basis and Whistleblowers are encouraged to disclose their identities, to obtain the protection afforded to them by law.