The vision of TCC Credit Co-operative Ltd (TCC) is “To be the First-Choice Credit Co-operative that provides innovative, fair and family-oriented financial services of quality and value”. To achieve our vision, it is crucial that all of our employees and partners understand, follow, and adhere to our corporate values which are Caring, Convenient, Fair, Flexible, Honest, Nurturing, Reliable, Responsible and Responsive. We have put guidelines and policies in place to ensure we live by these values in our day-to-day work.
Together with our values, we want to have feedback and encourage people to speak up when they see activity or behaviour that they feel is wrong or does not match our values. The goal of this policy is to provide very clear guidelines on how we approach and manage this feedback. With our whistleblowing policy, we aim to ensure:
Every employee should have the chance to speak up anonymously when they feel we are not adhering to our corporate values. They should have a place to report misconduct, every report will be heard and acted on, and we will make improvements based on the results.
TCC believes everyone should be able to make reports anonymously. We commit to protecting informant’s identities and they only need to reveal themselves if they choose to.
We will investigate every report of misconduct. At the end of the investigation, we will document the results and provide feedback when appropriate.
1.2 Our Commitment
TCC wants our employees to know they can provide information on any concerns they have, understand where they can report their concerns, know what happens after they make a report, and ensure they feel safe in providing a report. TCC also wants to let them know about their right to be anonymous as well as how we, as an organization, will ensure they are not subject to any retaliation or other abuse because they made a report.
1.3 What Conduct Should Be Reported
It is important that TCC outlines what behaviour we want to be reported under this policy. We want to hear from you if you witness or know about any behaviour that is:
Violates the law or any legal code;
Is creating an unsafe environment;
Breaches any of our company’s policies;
Sexual Harassment and/or bullying of any kind;
Any conduct which is detrimental to TCC and could cause financial or non-financial loss
1.4 Who Falls Under This Policy
The following would be considered an “eligible person” and would fall under TCC’s whistleblowing policy.
Employees (managers, executives, officers and interns);
Contractors, consultants, service providers, suppliers, business partners;
Members of TCC Credit Co-operative Ltd
This policy applies to all TCC’s businesses, divisions, and offices. If local legislation, regulation, or laws provide a higher level of protection than what is included in this policy, the local legislation will take precedence.
2. Process for Making a Report
2.1 What Options Do Employees Have For Making a Report
If an employee or eligible person would like to make a report, they can make the report by sending it through post or by email.
TCC respects and protects your identity if you choose to make an anonymous report. You can choose to remain anonymous while making a report, interacting with case managers during an investigation of your report, as well as after your case is closed. At any given time you can identify yourself, but this is your choice and at no point do you need to do this or will you be forced to provide your identity.
If you decide to disclose your identity, TCC will work to protect your identity and will outline and document who in the organisation will know you submitted your report. TCC will also take all steps necessary to ensure you do not suffer any retaliation.
It is worth noting that TCC will make every endeavour possible to investigate your report, but in some cases, there are limitations of what can be achieved if the informant decides to remain anonymous.
2.3 What Is The Investigative Process?
It is important for TCC to be transparent with our employees and outline what is the process for us to investigate a report submitted through our whistleblowing channels. Below, we have provided the different steps a case manager or member of our whistleblowing team will go through once a report is received until the case is closed.
Report (anonymous or otherwise) is received.
The Chairman or General Manager to assess it and confirm its receipt.
The Chairman or General Manager will do an initial assessment to confirm it is a valid report and request permission to investigate.
The Chairman or General Manager will begin their investigation. This can include corresponding with the informant if there is a channel to do this.
Once the Chairman or General Manager has finalised their investigation and report, the informant will be updated.
At this point, the Chairman or General Manager will submit the complete report to the Board of Directors for any subsequent action to take place.
2.4 Use 3rd Parties
At TCC, we may utilise 3rd parties in our whistleblowing program and strategy. The Chairman of TCC will assess the report and will decide if the use of 3rd party will be required to investigate the report. Examples of how we might utilise 3rd parties include:
Accounting Firms: TCC uses 3rd party accounting firms to do forensic investigating of specific reports that come through our whistleblowing program.
Investigative Firms: TCC uses specialist investigative firms to investigate specific cases where we do not have the skills needed in-house. They are also used for investigations that we would prefer a 3rd party execute on due to the nature of the report.
Human Resources Consultants: TCC utilises human resources consultants across our business and they might be involved in specific whistleblowing cases, ensuring we use human resource best practices as we assess, investigate, and take action.
2.5 Who Is Alerted To a Report
Once a report is submitted (anonymous or not), this report goes to General Manager or the Chairman. The General Manager will manage the investigation unless the report is against the General Manager, then the Chairman or a Director of the Board appointed by the Chairman will manage the investigation.
Certain senior managers might be alerted to the report as part of the reporting process or if they are involved in the investigation in some manner.
Any information that could potentially identify an anonymous informant will be held in the strictest confidence and will not be shared, unless TCC is compelled by law.
2.6 What Is The Process Of Updating The Informant
As part of our investigative process, TCC will update the informant of the progress of the investigation. These updates can include the following:
TCC has confirmed the receipt of a report from the informant.
TCC has begun the investigative process.
The investigation is currently ongoing.
The investigation has been closed.
TCC’s commitment is that the informant will be updated once a month while the investigation is ongoing. They will then be updated once the investigation has been closed.
TCC will strive to provide as much feedback on the investigation as possible. However, due to TCC’s privacy guidelines, there could be information that may not be shared with the informant.
2.7 What If the Informant Is Not Satisfied With The Result
If, after receiving the summarised report of the investigation, the informant is not satisfied with the result, they can escalate this to the Chairman of the Board. The informant can provide this escalation in writing so that a formal review can take place. While the Chairman commits to review the request, TCC is under no obligation to reopen the investigation. If the Board of Directors conclude that the investigation was conducted properly and no new information exists that would change the results of the investigation, the investigation will be concluded.
3. How Informants Are Protected
3.1 Anonymity after Submitting a Report
Section 2.2 discussed how an eligible person can remain anonymous during the process of submitting a report. After submitting a report, the following policies around anonymity are in place to protect an informant’s identity.
The informant has the right to remain anonymous and does not need to identify themselves at any time during the investigation process.
TCC will exercise strict confidentiality in processing the report to protect the informant’s identity during and after submitting a report.
At no time TCC will force the informant to reveal their identity.
The informant can refuse to answer questions they feel could identify themselves. If the informant reveals themselves at any time, TCC will document who will have access to their identity. This can include the case manager, whistleblowing program owner, etc.
3.2 Potential Retaliation
An informant might be concerned that staff, management, or the organisation might retaliate against them. In this case, TCC will protect the informant from:
Being terminated or having their employment ceased;
Harassment on the job or workplace bullying;
Warnings or disciplinary actions;
Any other action that can be perceived as retaliation for making a report;
3.3 Considered Risk of Retaliation
In the case of “considered risk of retaliation”, the informant believes retaliation is near or imminent, and they are targeted for retaliation. In cases of considered retaliation, the informant should contact the General Manager. The General Manager will take the action they feel is appropriate as well as come up with recommendations for how the situation can be resolved. Potential steps to protect the informant from a considered risk of retaliation can include:
The informant taking leave.
The informant being reassigned to other duties.
The informant being reassigned to another location.
3.4 Already Retaliated Against
If the informant feels that they have already been retaliated against, they should escalate this immediately to the General Manager. The General Manager will take the action they feel is appropriate as well as come up with recommendations for how the situation can be resolved. Potential steps to protect the informant after retaliation has occurred can include:
The informant taking leave.
The informant being reassigned to other duties.
The informant being reassigned to another location.
3.5 Retaliation Not Adequately Resolved
If the informant feels their report of retaliation was not resolved adequately can escalate this case in writing. The report will need to go to Board of Directors and they will investigate the matter and process for how the retaliation was dealt with.
3.6 How TCC Deals With Retaliation
TCC does not tolerate any attempts to retaliate against an informant who has made a report. Any employee or associated person that found retaliating will face disciplinary action, including the potential to be terminated from their roles.
3.7 Separation of Issues
TCC will be able to still raise any issues related to work or performance-related issues. While TCC will protect the informant from any retaliation, it is also important that they are still effective in their job. TCC can still raise any performance or contract issues with the informant as long as they are kept separate and not influenced at all from any reports that have been made.
3.8 Protection & Immunity for Others
Other parties that might have to bear witness or are involved in the investigation will be protected from retaliation in the same manner as the informant.
4. Our Roles & Responsibilities
The roles within TCC’s whistleblowing program include the following:
General Manager (Whistleblowing protection officer (WPO));
Board of Directors of TCC’s whistleblowing program;
Human resources who are involved in cases and made aware of specific investigations.
The following are the responsibilities of each role in TCC’s whistleblowing program.
General Manager (Whistleblowing protection officer): This individual facilitates the entire program and is measured on its overall success. This includes employees knowing and understanding the program, an easy process of making a report, investigating reports, as well as being a point of escalation for any concerns or retaliation that has taken place. While this individual reports into the organisation, the result of the work goes directly to the Board of Directors.
The Whistleblowing Protection Officer views incoming anonymous reports and manages them as they conduct investigations. This person is the first line of escalation and works to ensure anonymous reports are heard and acted upon. His role is to investigate these reports. This includes interacting and asking questions of informants, as well as using the information provided to investigate the report submitted. The investigation can be internal or external to the organisation depending on what was documented in the report. The goal is to gather the facts and put forth a final report to the Board of Directors on what happened and what action they feel needs to take place.
Board of Directors: The Board of Directors are the owners of the program. They make the final decision based on the final report submitted by the Whistleblowing Protection Officer.
Human resources: Colleagues from human resources may be called upon to provide advice and guidance during any investigation. The whistleblowing program leverages their expertise and acumen to ensure TCC is using the best HR practices during investigations and we are treating all employees fairly.
5.1 Changes to TCC’s Whistleblowing Policy
From time to time, TCC’s whistleblowing policy will need to change to keep up with our values, best practices, improvements, as well as legislation and regulations. Any changes to our whistleblowing policy will be communicated with all employees and any relevant stakeholders. This policy and any changes made shall form any contract of employment.
Any changes to TCC’s whistleblowing policy must be approved by the:
Board of Directors
All changes will be reviewed by the Board of Directors and the Board can comment and provide feedback as necessary. All changes will also be documented in TCC’s whistleblowing policy and will be made available to all employees.
5.2 Reporting to the Board of Directors
The Board of Directors is updated every quarter on TCC’s whistleblowing program, inclusive of reports, investigations, and results. Reports or investigations carrying an undue amount of risk will be reported to the Board of Directors outside of the quarterly updates. The Board of Directors at any time can ask about anonymous reports, investigations, as well as the state of TCC’s whistleblowing program.
TCC’s whistleblowing program resides in the Establishment Committee. They are responsible and accountable for the implementation and effectiveness of TCC’s whistleblowing program.