The Merkin Group’s Whistle Blowing Policy adopted 10 Nov 2016

Whoever we may deal with in any of our businesses, and wherever we may operate, we are committed to doing so lawfully, ethically and with integrity.

It is the responsibility of each and every one of us at The Merkin Group to ensure that we fulfil this commitment in our day to day working lives.

However, from time to time there may be situations where the right course of action is unclear, or there may be situations where someone on ur team suspect or know that something is improper, unethical or inappropriate.

We acknowledge that we  have both a legal and moral duty to take appropriate measures to identify such situations and attempt to remedy them.

It is sometimes difficult to know whether to speak up about something that concerns us. Often people are reluctant to get involved but this could result in serious consequences for The Merkin Group  and its employees. That is why we have put in place a comprehensive  Whistle Blowing Policy – so that anyone on our  can talk to someone confidentially so that we can help.

This Policy has been established to ensure that all cases of suspected wrongdoing are reported and managed in a timely and appropriate manner and we are committed that we will ensure that all matters are dealt with in a timely manner, with sensitivity and by the appropriate person.

POLICY AIMS

The aim of our policy is to:

• Ensure all employees feel supported in speaking up in confidence and reporting matters they suspect may involve anything, improper, unethical or inappropriate;
• Encourage all improper, unethical or inappropriate behaviour to be identified and challenged at all levels of the organisation;
• Provide clear procedures for the reporting of such matters;
• Manage all disclosures in a timely, consistent and professional manner; and
• Provide assurance that all disclosures will be taken seriously, treated as confidential and managed without fear of retaliation.

APPROVAL AND ADOPTION 

This policy, which has been approved by by the Board of Directors of Merkin Pastoral Holdings Pty Ltd – the Group parent is a statement that improper, unethical or inappropriate behaviour within the organisation is unacceptable and this statement is endorsed and supported at the highest level.

 WHEN SHOULD I SPEAK UP?

This policy is designed to deal with concerns raised in relation to specific issues which are in the public interest and detailed below. Only genuine concerns should be reported.

Whistle blowing means a disclosure of information made by an employee or contractor, an external person or body where they reasonably believe that one or more of the following matters is happening now, took place in the past or is likely to happen in the future. This is a non – exhaustive list of examples:

• A criminal offence;
• Fraud;
• A failure to comply with a legal obligation (e.g. breach of a contractual or other common law obligation, statutory duty or requirement or administrative requirement, including suspected fraud, malpractice or breach of the Informa Code of Ethics);
• A miscarriage of justice;
• A danger to the health and safety of any individual;
• Damage to the environment; and
• A deliberate concealment of information tending to show any of the above.

The Merkin Group  has other policies and procedures that deal with complaints, critical or constructive comments, and appeals. Disciplinary, Grievance, Harassment and Equal Opportunities policies also address standards of behaviour at work.  Recently the Group has introduced Codes of Conduct and Anti – Bribery, Anti – Fraud, Corruption and similar policies to ensure that our framework supports our culture, ethics, values and integrity.

To view the Policy see hereTMG.Whistleblowing.Policy.10112016.V1