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(1) This procedure supports the Whistleblowing (Reporting Wrongdoing) Policy by outlining the processes to be followed for reporting, receiving, managing and investigating wrongdoing within Charles Sturt University (the University). (2) This procedure has the same scope as the Whistleblowing (Reporting Wrongdoing) Policy. (3) For the purpose of this procedure: (4) This procedure supports the Whistleblowing (Reporting Wrongdoing) Policy. (5) A report can be made in writing or verbally to any authorised disclosure officer listed in the Whistleblowing (Reporting Wrongdoing) Policy. Written reports are preferred as this can help to avoid any confusion or misinterpretation. (6) The University’s Reporting Wrongdoing website will also provide links to: (7) If a report is made verbally (except for reports made to the independent external hotline), the authorised disclosure officer will make a comprehensive record of the report and ask the person reporting the wrongdoing to sign this record. The reporter should keep a copy of this record. (8) When requested, the authorised disclosure officer will arrange to allow a person reporting a wrongdoing to make the report privately and discreetly, away from the workplace if necessary, and will discuss with the reporter any concerns they may have about potential reprisal or workplace conflict. (9) As stated in the Whistleblowing (Reporting Wrongdoing) Policy, wrongdoing may also be reported to the relevant external investigating authority. Contact details for each investigating authority are provided in the External Investigating Authorities list. (10) An authorised disclosure officer who receives a report of wrongdoing will: (11) Notwithstanding clause 10, where a report of wrongdoing is about the principal officer or the disclosure coordinator, the following will apply: (12) The University’s disclosure coordinator will assess the report and may determine that: (13) Where immediate action is required to protect the safety of people, animals or the environment, the disclosure coordinator will enact any relevant emergency management procedures. (14) Where the disclosure coordinator determines that the report will be investigated as a wrongdoing under the PID Act or Corporations Act, they will gather preliminary facts to determine whether there may be a case to answer. The disclosure coordinator may also delegate the preliminary appraisal to the disclosure manager. (15) The preliminary appraisal will be completed promptly to determine what action will be taken to deal with the report of wrongdoing, and the findings will be referred to the principal officer (except where the matter relates to the principal officer). (16) The disclosure coordinator will assess the preliminary appraisal, in consultation with the principal officer where appropriate, based on the information available to the disclosure coordinator at the time and: (17) Throughout all preliminary appraisals and investigations, the disclosure coordinator and/or disclosures manager will: (18) Where required, the disclosure coordinator or disclosure manager may seek advice from others within the University, including the Executive Director, People and Culture, General Counsel or Internal Audit staff, while maintaining the confidentiality as far as practicable. (19) Subject to the direction of the Independent Commission Against Corruption (ICAC), all formal investigations relating to corrupt conduct within the University must be assigned, by the disclosure coordinator or principal officer, to a suitably qualified investigator (such as a certified fraud examiner or similar). The principal officer will refer investigation reports to the ICAC. (20) Unauthorised investigations by line managers or by any member of staff are prohibited. (21) People who report wrongdoing will be advised of what is happening in response to their report (except where a report is made anonymously or without contact information). (22) When a report is made, the authorised disclosure officer or the disclosure coordinator will contact the reporter to confirm that the report has been received and to advise: (23) Within 45 calendar days of the report being made, the disclosure coordinator will send the reporter an acknowledgement letter, providing: (24) If the report is made that meets the requirements of the PID Act, but is made under a statutory or legal obligation or is incidental to the performance of the reporter’s day to day functions, an acknowledgement letter or a copy of this policy will not be provided. (25) While a report is being dealt with, such as by investigation or making other inquiries, the person who made the report will be given: (26) Once the matter has been finalised the person who made the report of wrongdoing will be given: (27) The University will not tolerate detrimental action in reprisal against a person who reports wrongdoing or is believed to have reported wrongdoing. (28) Detrimental action means action causing, comprising or involving any of the following: (29) The PID Act and Corporations Act provide legal protection for people who have reported wrongdoing in accordance with the criteria under those acts. Penalties apply to anyone who takes detrimental action against another person substantially in reprisal for that person making a report under those acts. These penalties also apply to cases where a person takes detrimental action against another because they believe or suspect the other person has made or may have reported a wrongdoing, even if they did not. (30) A person who is found to have committed a reprisal offence may face criminal penalties such as imprisonment and/or fines and may be required to pay the victim damages for any loss suffered as a result of the detrimental action. (31) Taking or threatening detrimental action against a person substantially in reprisal for that person making a report under the Whistleblowing (Reporting Wrongdoing) Policy and this procedure is also misconduct which may result in disciplinary action under the Enterprise Agreement. (32) If a report of wrongdoing made under clause 14m. of the Whistleblowing (Reporting Wrongdoing) Policy is determined not to be a protected disclosure under the PID Act solely because it is made to an external service provider: (33) If a person believes that detrimental action has been or is being taken against them or someone else in reprisal for reporting wrongdoing, they should tell their supervisor (where they are a staff member), the disclosure coordinator, or the principal officer immediately. (34) Supervisors must notify the disclosure coordinator or the principal officer if they suspect that reprisal against a staff member is occurring or has occurred, or if any such allegations are made to them. (35) If the University becomes aware of or suspects that reprisal is being or has been taken against a person who has reported a wrongdoing, the University will: (36) If a person who has reported wrongdoing alleges reprisal, they will be kept informed of the progress and outcome of any investigation or other action taken in response to the allegation. (37) If a reporter of wrongdoing experiences reprisal which they believe is not being dealt with effectively, they may contact the NSW Ombudsman or the ICAC (if the report relates to corrupt conduct). Contact details for these investigating authorities are included at PID schedule - Disclosure contacts and investigating agencies. (38) If a report of wrongdoing satisfies the requirements for a protected disclosure under the PID Act or the Corporations Act, the person making the report will be protected against certain legal actions related to making the report. A person who makes a protected disclosure may rely on the protection under those acts in their defence against any action, claim or demand taken or made against the reporter for having made the disclosure. The reporter will not have breached any confidentiality or secrecy obligations and the reporter will have the defence of absolute privilege in defamation. (39) The protections under the PID Act and Corporations Act are essentially protections against reprisals that may be made against a reporter because he or she has made a report of wrongdoing in accordance with those Acts. However, this does not extend to any wrongdoing on the part of that reporter. (40) The University is committed to ensuring staff who are the subject of a report of wrongdoing are treated fairly and reasonably. This includes keeping the identity of any person the subject of a report confidential, where this is practicable and appropriate. (41) A person who is the subject of a report will be advised of the allegations made against them at an appropriate time and before any adverse findings. The subject of a report must be: (42) Where allegations against a person are clearly wrong, or have been investigated and are unsubstantiated, that person will be supported by the University. The fact of the allegations and any investigation will be kept confidential unless otherwise agreed to by the person who was subject to the report. (43) The University is committed to establishing and maintaining a working environment that encourages staff to report wrongdoing and supports them when they do. This includes keeping the identity of reporters confidential where practicable and appropriate and taking steps to protect reporters from reprisal and manage workplace conflict. (44) The University will take ownership of all reports of wrongdoing it receives and deal with them as stated in the Whistleblowing (Reporting Wrongdoing) Policy and this procedure. All reports of wrongdoing will be treated fairly and reasonably while respecting the rights of any officers the subject of a report. (45) All University staff have a responsibility to: (47) The Vice-Chancellor, as the principal officer, has ultimate responsibility for maintaining the internal reporting system and workplace reporting culture, and ensuring the University complies with the PID Act and Corporations Act. The principal officer is responsible for: (48) The disclosure coordinator is responsible for: (49) Authorised disclosures officers are responsible for: (50) Supervisors and line managers have a responsibility to: (51) A person reporting wrongdoing is required to: (52) Further information around reporting wrongdoing is available on the University’s website. Staff can also seek advice and guidance from the disclosure coordinator or the NSW Ombudsman’s website at www.ombo.nsw.gov.au. (53) The Whistleblowing (Reporting Wrongdoing) Guidelines provide further information for people considering making a report of wrongdoing.Whistleblowing (Reporting Wrongdoing) Procedure
Section 1 - Purpose
Scope
Section 2 - Glossary
Top of PageSection 3 - Policy
Section 4 - Procedures
Part A - Making and receiving reports
Making a report
Receiving a report
Investigation of reports
Part B - Feedback to people who report wrongdoing
Acknowledgement
Progress updates
Feedback
Part C - Protection against reprisals
Responding to allegations of reprisal
Protection against certain legal actions
Part D - The rights of the persons the subject of a report
Part E - Roles and responsibilities
Part F - More information
Section 5 - Guidelines