Please note this is not a complaints or information service.
Please be advised this disclosure channel is specifically for the purpose of reporting suspected illegal activity. Should you wish to provide any other feedback, please contact your designated Henley representative. Alternatively, please contact our reception team who will connect you with the relevant department. General queries will not be responded to via this disclosure channel.
We have zero tolerance for misconduct or unethical behaviour. It has serious implications for our people, business operations and reputation.
Have you seen something that doesn’t seem right? If so, do the right thing and speak up. Our whistleblower protection procedure has been adopted to ensure that people can raise concerns without fear of reprisal or feeling threatened in the process.
Disclosable conduct
Disclosable Conduct is any matter/information that you have ‘reasonable grounds’ to suspect concerns misconduct or an improper state of affairs or circumstances in relation to Henley.
Examples of Disclosable Conduct are:
- Dishonest or corrupt behaviour, including soliciting, accepting or offering a bribe, facilitation payment or other such benefit or inducements.
- Any offer of gifts to public officials.
- Fraudulent activity.
- Illegal activity (including theft, prohibited trade practices; prohibited drug possession, sale or use; violence or threatened violence and property damage).
- Improper behaviour relating to accounting, internal accounting controls, actuarial, or audit matters.
- An activity that poses a substantial risk to the environment, any building or operation.
- Conduct that endangers health or safety.
- Unethical dealing with a customer, supplier or member of the public.
Information to include
When making a disclosure you should consider providing as many details as possible to assist us to determine the best course of action. These may include:
- Nature of the wrongdoing
- Details of the person and anyone else you think committed the wrongdoing
- When and where the wrongdoing occurred
- If you did anything in response to the wrongdoing
- Any supporting information
- Your name and contact details (recommended, however not mandatory and anonymous disclosures can be made, however we will not be able to report back to you if we do not have your details).
Your information should be factual and avoid speculation, personal attacks and emotive language. To avoid jeopardising an investigation, you must keep confidential the fact that a report has been made (subject to any legal requirements).
Anonymous disclosures
When making a disclosure you can choose to identify yourself or make an anonymous disclosure. By identifying yourself, investigators will have the opportunity to clarify information or gather new information you may have. We may not investigate if there are insufficient grounds on which to base an investigation. Where contact details are not provided, additional information cannot be obtained should that be necessary. Anonymous disclosures do not receive updates regarding the outcomes of investigations.
How we deal with your information
All information is sent direct to our Whistleblower Protection Officer (WPO) and our General Manager of People and Culture (GM-PC). They will review your information and if a valid disclosure, advise the Chief Executive Officer and together they, and any other relevant Henley representatives, will determine the appropriate course of action, which could include referring it for preliminary investigation or determining that the report is baseless or unfounded and that no further investigation is warranted.
The WPO must ensure that all valid claims are taken seriously and investigated fairly. The WPO will also ensure that where you have requested that you wish to remain anonymous, that your details are not provided to any other person in the business (aside from the GM-PC and the WPO) without your consent.
Where a formal investigation is required, Henley will take all reasonable steps to ensure that the investigation is conducted fairly, independently, without bias, in a timely manner and in accordance with the principles of natural justice. All reasonable efforts will be made to preserve the confidentiality of the investigation and the identity of the parties involved.