Open Talk

The ABN Group Open Talk Policy provides an avenue for all employees of the Group and members of the public to disclose any improper conduct committed or about to be committed by an employee or external party engaged by the ABN Group.

Please note that this is not a complaint or information service.  For complaints or information, please phone the respective ABN Group Company and your concerns will be addressed appropriately.

Disclosures under the Open Talk Policy can also be made directly to our nominated Open Talk Officer, Matthew England, Legal Practice Director (WA Workplace Law Pty Ltd) at 08 9204 3677 or matthew.england@wplaw.com.au.

Information to include

When making a disclosure you should consider providing as many details as possible to assist us in determining the best course of action, such as:

• The nature of the wrongdoing
• The details of the person you think committed the wrongdoing
• When and where the wrongdoing occurred
• Any relevant events surrounding the wrongdoing
• Anyone else aware of or involved in the wrongdoing
• Anyone else who may verify the claims
• If you did anything in response to the wrongdoing
• If you are concerned about a possible reprisal
• Any supporting information (e.g. documents, file notes)
• Your name and contact details (recommended, however anonymous disclosures can be made)

Your information should be clear and factual. Avoid speculation, personal attacks and emotive language.

Anonymous Disclosers

When making a disclosure you can elect to either identify yourself or make an anonymous disclosure. By identifying yourself, investigators will have the opportunity to clarify information or gather new information you may have.

If there are insufficient grounds on which to base an investigation, the ABN Group may not be able to sufficiently investigate. Where contact details are not provided, additional information cannot be obtained should that be necessary. Anonymous disclosures do not receive updates regarding the outcomes of investigations.

How we deal with the information provided

The authorised person receiving the complaint under the ABN Group Open Talk Policy will give consideration to the concern/allegation raised based on the following factors prior to initiating any investigation;

• Seriousness of the issue raised
• Credibility of the concern
• Amount and details of information provided
• Availability of documentary evidence (if any) disclosed

We may contact you by phone (if you have given us those details) and follow up with you to obtain the information you have. We will keep that information and your identity confidential.

However, in very limited circumstances – for example, if a court subpoenas us to do so – we may be compelled to provide it. If this happens, we will speak with you about that ahead of time and always seek to protect your identity and disclosure.

When we will act on your information

All information, matters raised or reports of alleged wrongdoing and breaches of legislation will be assessed initially by the authorised person receiving the complaint or by ABN Group’s Open Talk Officers. In the process of our assessment, we will need to take an objective view of the information provided and consider if the core allegation is something we need to make further inquiries about or act on.