Whistle blowing procedure
Why a fraud hotline?
Tshikululu established the hotline to provide its stakeholders (consumers, suppliers, employees, operators, transporters & the public) with a mechanism whereby they could voice any suspicion of unethical behaviour totally anonymously, without fear of victimisation in any way.
This hotline is part of Tshikululu’s commitment to zero tolerance against dishonest and unethical behaviour of any of our stakeholders.
What is whistle-blowing?
Whistle-blowing is about “raising a concern about unethical or dishonest conduct within an organisation, or outside an organisation, and which conduct has an impact on the organisation’s operations”. It is a key tool to promoting individual responsibility and organisational accountability in combating fraud and corruption.
Who make use of the hotline?
The whistleblowing hotline is for all stakeholders. Tshikululu perceives all persons with knowledge of fraud, corruption and unethical behaviour that has an impact on the company and its operations, as its stakeholders.
What should be reported through this hotline?
Any knowledge or suspicion of unethical behaviour. Unethical behaviour is a collective term that includes fraud, corruption, theft, nepotism, conflicts of interest, non-compliance with the Tshikululu rules and regulations, favouritism, discrimination, abuse of position, and any dishonest behaviour.
What should not be reported through this hotline?
Any issues solely related to HR, i.e. complaints about bonuses, remuneration, promotions, grievance procedures, etc. Tshikululu has internal policies and procedures available for these complaints.
Any issues solely related to
- delays in issuing of permits, or
- complaints about conduct not falling within the ambit of Tshikululu, such as conditions of roads, traffic offences, etc.
Must I be able to prove my suspicion before calling the hotline?
No. The information contained in your report will be verified and followed up by experienced investigators. You only need to have a reasonable suspicion. This means that you must have information at your disposal (which may yet be unproven) that triggered your suspicion of somebody acting dishonestly or unethically.
What is going to happen to my report?
Legal experts will review your report, and experienced investigators will investigate the suspicion. If the investigation culminates in evidence indicating any criminal, civil or labour law contraventions, Tshikululu will take the necessary action in line with its commitment to zero tolerance.
How and where can I report my suspicions?
Your suspicion(s) can be reported in any of the following ways:
Will I remain anonymous?
Yes. The call centre (including the fax, postal and email reporting options) is hosted and managed by an external service provider, off site. Strict confidentiality rules apply, even if you provide your personal details to the call centre agents, on the condition that its disclosure is allowed only to the investigators.
If you do not provide your personal details to the call centre agents, they would not know your identity, and there will be nothing to disclose. The call centre agents are experienced, and strict confidentiality rules have been included in their employment agreements.
If you wish to remain anonymous, take care to not disclose the information at your disposal in a way that may give away your identity.
By saying “… in the 33 years I have been employed as …”; or “…from my office adjacent to Peter’s …” you will certainly risk being identified!
Only the external service provider
- has keys to the Post Office Box where reports may be made through the postal system
- has access to the free fax number
- has access to your ‘please call me’ (sms call-back facility)
- has access to the toll-free telephone number (fielding the calls); and
- has access to the email address reports are emailed to.
Using the web-mail reporting facility results in an email sent to an email address only the external service provider has access to.
If I select to disclose my identity, will I be protected against victimisation?
Yes, if you are bona fide (genuine) in submitting your report. This means that you should not have any ulterior motives for reporting and act in good faith (e.g. not conjuring a report against somebody based on revenge etc.). Your suspicion should also be reasonable (see question 6 above for what amounts to a reasonable suspicion).
All whistle-blowers should bear in mind that the victimisation of whistle-blowers is illegal, may amount to misconduct (which is a dismissible offence in terms of the Labour Relations Act), and may even result in civil litigation.
Tshikululu subscribes to the protection afforded by the Protected Disclosures Act, and the upholding of the principles against any form of victimization as contained in King IV. If you want to know more about the protection afforded by the Act, please visit the website of the Open Democracy Advice Centre (ODAC) at www.opendemocracy.org.za.
ODAC is a section 21 company, whose mission is to promote transparent democracy, foster a culture of corporate and government accountability, and assist people in South Africa to realise their human rights, specifically relating to whistle-blowing, and the protection afforded by the Protected Disclosures Act. To this end, ODAC has established a helpline through which free, independent and confidential advice is provided to individuals, organisations and businesses which have concerns about misconduct and criminal or unethical conduct in the workplace. The helpline number is 0800 525 352 (0800 LALELA). You may also submit questions to ODAC through its web-based helpline available on their website. You may also report perceived victimisation to the call centre, which will be investigated.
If I decide to report my suspicion, what information will I be asked to provide?
Whistle-blowers should bear in mind that the objective of the Ethics Line is to utilise the information contained in the reports in an investigation. Thus, there should be sufficient detail to enable the following up of this matter. You will be asked to provide as much detail as possible, as this will assist the investigators in successfully concluding the investigation. For an idea of what will be asked (or what information you should provide if you opt to report via the Post Office Box), please visit the Vuvuzela website at www.thehotline.co.za, where a list of questions is provided.
If you are unsure whether you have sufficient information, we advise that you still report the matter regardless.
Can I obtain feedback on what has happened to my report?
Yes. Tshikululu subscribes to effective communication, and you may require feedback by calling the call-centre on the same number you used for your report. Please note that, to protect your identity as a whistle-blower, no information will be given out without the caller providing a password, and the reference number of the call. The password is the same password provided by the caller when the report had been submitted initially.
Feedback may also be requested through the website www.thehotline.co.za. We encourage you to make use of a free email service (such as Gmail.com) to create a temporary email account using a pseudonym, so that the investigators may correspond with you as necessary. This may be helpful in providing you with feedback and pursuing your suspicion.
It’s your call!
|Postal||PO Box 10129, Valhalla, 0137|
|Fax||086 726 1681|
|SMS / Call-Back||072 595 9139|