Date Approved: July 2018
Effective From: July 2018
Future Review Date: tbd
Application: This policy applies to all NZX listed companies.
Purpose: NZSA maintains a range of policies to positively influence the behaviour of all participants in the NZX listed company sector. These policies should be read in the context of the NZSA Policy Framework Statement.
This policy document dates from July 2018.
1.0 Policy: Employee Engagement and Whistleblowing
1.1 The Association recommends that all companies have an appropriate policy around employee engagement including the safe reporting of illegal and other inappropriate behaviour.
1.2 The company should disclose its policy, or explain why it doesn’t have a policy in its Annual Report.
1.3 Where the company has a policy, it should also disclose sufficient details of the mechanisms which allow employees to report such behaviour in a manner that will inform a reader of the report about the efficacy of the policy.
2.1 The Association believes that companies that have engaged employees will produce better results benefitting all stakeholders and in particularly shareholders.
2.2 Part of achieving better engagement is for employees to have a safe process to report genuine illegal or other inappropriate behaviour that may harm the company and the employees. This is commonly known as “whistle blowing”.
2.3 In addition to the Protected Disclosures Act 2000, there is other legislation and regulation around Health and Safety and financial conduct appertaining to the NZX and Financial Markets Authority. The Association believes that where appropriate for the company, employees should have access to a suitable employee assistance programme which will ensure they suffer no adverse consequences as a result of drawing illegal or inappropriate behaviour to the Company’s attention.
3.0 Voting Discretionary Proxies
Where it can be demonstrated that harm was caused and the company concerned did not have an appropriate policy around employee engagement or failed to uphold this, the NZSA will consider appropriate voting against the re-election of Directors..
Policy 21 – Independent Advice for the Board