[Ws2-transparency] WS2 Transparency Thematic Discussion: Whistleblower Protection

[Michael Karanicolas]

Hi,

Further to my last email, please find our current working document on
whistleblower protection. Look forward to hearing your ideas for this.

Michael

*1.    **Improvements to the existing whistleblower policy *

a.      Clarity and availability of the existing policy, and employee
education around it.

  i.     International dialing numbers are included in a list at the end of
the Hotline Policy; however, the reference to these dialing/access numbers
on page 2 of the Hotline Policy do not specify where to find this list.

b.     What counts as a whistleblower? Types of incidents reported:
accounting irregularities, unethical conduct, abuse of authority, etc.

   i.     Reporting is limited to “serious issues”

  ii.     The Hotline Policy scope is limited to employees.

c.      Operation of whistleblower system – how/when to make a report; who
investigates the report, reporting methods (hotline, online, etc.),

 i.     No case management software is currently being used

 ii.     Information about the system’s operations is difficult to locate
(ex – stats on reporting).

 iii.     Low use - The Hotline has received only 3 reports since its
inception in 2008.

d.     What protections and remediation does the system provide?

 i.     Anonymity limited “to the extent allowed by local law”

 ii.     Protection of good faith reporting is not specifically mentioned

e.      What sort of oversight or protections mechanism is in place –
internal department (HR, Legal counsel, other) vs. external retention of
3rd party specialist

f.       Transparency – is there an external audit for how whistleblowers
have been handled, and how are employees and the public made aware.

g. How are operational conflicts of interest resolved
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