Global Whistleblowing Policy

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Which policy do I report under?

You should report all concerns under the Global Whistleblowing Policy unless your disclosure:

  • falls within the scope of AirTrunk’s Japanese or Australian Whistleblowing Policies (see below); or
  • relates to inappropriate workplace behaviour and personal grievance matters (see below).

Report under the Australian Whistleblowing Policy, if your disclosure concerns AirTrunk’s Australian operations and:

  • you come within that policy’s definition of an ‘eligible whistleblower’; and
  • your disclosure meets that policy’s definition of a ‘protected report’.

Typically, disclosures that you make under the Australian Whistleblowing Policy will relate to concerns regarding serious misconduct such as fraud, bribery or corruption involving AirTrunk’s Australian operations.

An example is reporting a concern that an employee within the Australian business is paying bribes to win business for AirTrunk.

Report under the Japanese Whistleblowing Policy, if your disclosure concerns AirTrunk’s Japanese operations and:

  • you come within that policy’s definition of a ‘whistleblower’; and
  • your disclosure meets that policy’s definition of a ‘concern’.
  • Disclosures that you make under the Japanese Whistleblowing Policy will relate to any concerns regarding AirTrunk’s Japanese operations including any concerns you may have relating to inappropriate workplace behaviour that is occurring within AirTrunk’s Japanese operations.

Report under the Appropriate Workplace Behaviour Policy and Complaints Procedure, if your disclosure:

  • relates to inappropriate workplace behaviour; and
  • not otherwise caught by the Australian or Japanese whistleblowing policies.

Disclosures that you make under the Appropriate Workplace Behaviour Policy and Complaints Procedure will relate to concerns regarding inappropriate workplace behaviour such as discrimination, bullying and harassment.

An example is reporting a concern that an employee within the Hong Kong office is being harassed or bullied by a senior manager.

1. Introduction

  1. AirTrunk is committed to ensuring the highest standards of conduct in all of its activities by:
    1. promoting and actively developing an enhanced culture of honesty, integrity, ethical behaviour;
    2. conducting our operations lawfully and responsibly;
    3. preventing and detecting suspected misconduct and illegal or unethical behaviour; and
    4. reviewing our operations and standards to ensure their continuous improvement.
  2. AirTrunk encourages the reporting of suspected misconduct within the company so that it can be dealt with appropriately.
  3. AirTrunk will protect and support anybody who raises a concern in accordance with this Policy against detrimental conduct.
  4. The purpose of this Policy is to provide a channel for individuals who report wrongdoing to do so in a safe and secure manner where they will be protected and supported.

2. Interaction with other policies

  1. Please ensure that any matters that are:
    1. reportable under the Australian Whistleblowing Policy, are reported in accordance with that policy, rather than under this Global Whistleblowing Policy;
    2. reportable under the Japanese Whistleblowing Policy, are reported in accordance with that policy, rather than under this Global Whistleblowing Policy; and
    3. related to inappropriate workplace behaviour are reported under AirTrunk’s Appropriate Workplace Behaviour Policy and Complaints Procedure.
  2. It is important that you report your concern under the correct policy, so that you are able to obtain the appropriate protections afforded by that policy.
  3. The summary diagram above will help you to determine which policy you should report under. We appreciate that given the international nature of our business there are various reporting channels.  Please contact AirTrunk’s Chief Legal Officer, Lisa Cheng, if you have any questions about the operations of AirTrunk’s whistleblowing polices including which policy you should report under.
  4. The Australian Whistleblowing Policy and Japanese Whistleblowing Policy are available on AirTrunk’s website, and the Appropriate Workplace Behaviour Policy and Complaints Procedure is available on AirTrunk’s Intranet.

3. Who does this policy apply to?

  1. This Global Whistleblowing Policy applies to:
    1. all officers and employees of AirTrunk, past and present; and
    2. anyone who has or had any type of business relationship with AirTrunk, including agents, volunteers, business partners, contractors, suppliers and their employees.

4. What is reportable under this policy?

  1. You may report any issues or concerns regarding AirTrunk under this Global Whistleblowing Policy unless the issue or concern relates to:
    1. serious misconduct, such as suspected fraud or bribery that relates to AirTrunk’s Australian operations and is reportable under the Australian Whistleblowing Policy;
    2. AirTrunk’s Japanese operations, such as a breach of the company’s work rules, in which case your concern is reportable under the Japanese Whistleblowing Policy; and
    3. inappropriate workplace behaviour and personal workplace grievances, which are discussed in further detail at section 6 and are reportable under the Appropriate Workplace Behaviour Policy and Complaints Procedure.
  2. Examples of the types of issues or concerns that you may raise under this Global Whistleblowing Policy include:
    1. an AirTrunk employee in Singapore is concerned that another employee within the Singapore operations has committed fraud;
    2. an IT contractor in Hong Kong is concerned that an AirTrunk employee based in Hong Kong is bribing a government official for AirTrunk to receive preferential treatment in relation to working visas;
    3. an AirTrunk employee in Hong Kong observes an unsafe work practice in a AirTrunk data centre; and
    4. an AirTrunk employee in Singapore notices unauthorised or inappropriate use, or disclosure, of confidential company or client information by an IT Contractor.

5. What is not reportable under this policy?

  1. As explained above, all matters caught by the Australian Whistleblowing Policy, or the Japanese Whistleblowing Policy should be reported in accordance with the relevant policy to ensure that you receive the special protections available under Australian law and Japanese Law.
  2. Similarly, inappropriate workplace behaviours and personal workplace grievances are to be reported under AirTrunk’s Appropriate Workplace Behaviour Policy and Complaints Procedure. Examples of personal workplace grievances include:
    1. a conflict between two employees;
    2. a decision to transfer or demote an employee;
    3. a decision an employee’s terms and conditions of employment; or
    4. a decision to suspend or terminate a contractor.

6. How do you report under this policy?

  1. All disclosures will be directed to the Whistleblowing Officer, Lisa Cheng who is AirTrunk’s Chief Legal Officer.
  2. Disclosures can be made to the Whistleblowing Officer in person, by phone or by email to wb@airtrunk.com. Only the Whistleblowing Officer has access to that email address.
  3. If you would feel uncomfortable reporting to the Whistleblowing Officer or if there would be a potential conflict of interest in doing so (e.g., if the complaint was about a member of the Whistleblowing Officer’s team), then please direct your disclosure to the Alternative Whistleblowing Officer, Jennifer Zheng who is AirTrunk’s Head of Risk and Sustainability, in person, by phone or by email to wbalternate@airtrunk.com. Only the Alternative Whistleblowing Officer has access to that email address.
  4. You may make also make a disclosure on a named basis or anonymously by utilising AirTrunk’s external whistleblowing channel. To access this portal, please go to https://www.whistleblowingservice.com.au/airtrunk/. To make an “Online” report please click on the ‘Make a Report’ button below. You will be redirected to the new page where you need to enter ‘AIR2021’ in the ‘Unique Key’ field. Click on ‘next’ and follow the prompt. You will then be asked for will then be asked for your “Client Reference Number”, which is 2vcfz2021.
  5. When reporting anonymously, please consider how the Whistleblowing Officer or Alternative Whistleblowing Officer is to contact you moving forward, and please provide that contact method in your disclosure.

7. Investigation process

  1. Once a disclosure has been made to the Whistleblowing Officer or the Alternative Whistleblowing Officer, they will acknowledge the disclosure assuming you have left a contact method. They will then carry out an initial assessment to determine the scope of the investigation (i.e., what is it they are investigating and how will they investigate it). You may be required to provide further information as part of this assessment.
  2. The Whistleblowing Officer, or the Alternative Whistleblowing Officer if applicable, will have carriage of the investigation. They may appoint an external investigator, and/or solicitors, to complete and/or assist with the investigation. Your identity, if it has been provided, may be disclosed to these persons. They will take all reasonable steps to keep your identity confidential unless you consent otherwise, or disclosure is required by law.
  3. The Whistleblowing Officer and/or Alternative Whistleblowing Officer will keep you informed of the progress of the investigation and its likely timescale. All documents pertaining to the investigation will be kept in a secure and confidential location accessible only to those conducting the investigation.
  4. If the disclosure has been made to the Alternative Whistleblowing Officer, then it will be the Alternative Whistleblowing Officer who will have carriage of this investigation process – and the Whistleblowing Officer will not be made aware of the disclosure (and vice versa).

8. Protection and support offered to whistleblowers

  1. You may ask the Whistleblowing Officer and/or the Alternative Whistleblowing Officer to keep your identity confidential in which case AirTrunk will take all reasonable steps to ensure that your identity is not disclosed outside of the investigations team while the matter is investigated.
  2. As explained above, you may also raise your disclosure anonymously.
  3. AirTrunk will take appropriate measures to support your wellbeing during the investigation. These measures will be tailored to each case, and they might include:
    1. monitoring and managing the behaviour of other employees; and/or
    2. providing you with:
      1. alternative duties or an alternative role at the same level;
      2. paid time off work; and/or
      3. flexible working arrangements.
  4. AirTrunk will endeavour to ensure you do not suffer any detrimental treatment from AirTrunk employees as a result of making the disclosure. Detrimental treatment includes intimidation, harassment, discrimination, reprisals, demotion, disciplinary action and legal proceedings.
  5. AirTrunk discovers that you have been subject to such conduct it will take appropriate disciplinary action against the offending employee (up to and including dismissal).
  6. You will not be entitled to the protections if you have committed or were involved in the misconduct.

9. Procedural

  1. This Policy can be accessed on AirTrunk’s Intranet, or on AirTrunk’s website.
  2. The owner of this Policy is Chief Legal Officer.
  3. This Policy will be reviewed every two years.

10. Associated Policies

  1. Associated AirTrunk policies include:
    1. Australian Whistleblowing Policy;
    2. Japanese Whistleblowing Policy;
    3. Appropriate Workplace Behaviour Policy and Complaints Procedure;
    4. Anti-bribery and Corruption Policy;
    5. Gifts and Entertainment Policy; and
    6. Modern Slavery Policy.