Whistleblowing Policy

Whistleblowing Policy – NZ Shareholders Association

This is our Whistleblowing Policy, with effect from June 1, 2022.

NZSA has published this internal policy document in the interests of transparency for its members and stakeholders.

Objectives

The aims of this policy are:

1. To ensure that NZSA maintains the highest standard of conduct and ethical behaviour.
   
   
2. To ensure that NZSA maintains compliance with legal requirements in New Zealand in undertaking its activity.
   
   
3. To allow the reporting of alleged unethical, illegal or fraudulent conduct or other serious wrongdoing in a manner that maintains confidentiality and does not result in any disadvantage or reprisal for the individual making a report.

Policy Statement

1. An employee making an allegation of unethical, illegal or fraudulent conduct or other serious wrongdoing, should in the first instance contact the Chair. 
   
   
2. The Chair will undertake an initial investigation.
   • The Chair may involve another Board member as appropriate.
   • Depending on the nature of the allegation, the Chair may refer the matter to Police or other authorities.
     
     
3. The Chair will usually offer the target of the allegation an opportunity to comment prior to any referral or taking further internal action.
   
   
4. The employee making the allegation may report the allegation directly to an appropriate authority and/or another Board Member(s) where:
   • They believe, on reasonable grounds, that the Chair may be involved in the alleged wrongdoing;
   • No action has been taken by the Chair within 20 days after the initial reporting of the alleged wrongdoing.

Commentary

1. This policy is based on the ability of employees to make a protected disclosure under the Protected Disclosures Act 2000 to the Ombudsman (https://www.ombudsman.parliament.nz ).
   
   
2. The purpose of the Act is to promote the public interest:
   • by facilitating the disclosure and investigation of matters of serious wrongdoing in or by an organisation; and
   • by protecting employees who, in accordance with the Act, make disclosures of information about serious wrongdoing in or by an organisation.
     
     
3. Employees who wish to disclose this serious wrongdoing may do so and be protected by the Act from any civil or criminal liability in respect of the disclosure, provided the employee acts in accordance with the Act and he or she reasonably believes the information to be true.
   
   
4. Employees are required to follow the procedure set out in this policy in order to be protected under the Act.