|Document Reference Number
|Date of Creation
||Haya Water employees, former employees, Suppliers, customers and contractors.
||Internal Audit Department
||Board of Directors
||7 March 2011
Haya Water Board of Directors and its Executive Management are committed to ensure compliance with all its policies, procedures and adherence to all applicable laws and regulations. In line with that commitment, they encourage employees to raise their concerns if they encounter or suspect any misconduct or wrongdoing. Employees are a prime source of information when it comes to knowledge of any misconduct or wrongdoing that occurs within the organisation. They play a vital role in protecting the organisation’s information and assets. However, they may not raise any concerns out of fear of harassment or victimisation. In such situations, they may choose to overlook the concern rather than reporting it.
The risk of employee misconduct or wrongdoing can affect the organisation’s business objectives. Haya Water expects its employees, suppliers, contractors and customers to report to the organisation if they are aware of or suspect any misconduct or wrongdoing. Without their cooperation and initiative most misconduct may never be either detected or prevented. Every employee has a responsibility to report any such occurrence that they might come across. Withholding information and failure of reporting is considered to be collaborating with such misconduct and will be taken seriously. This whistle blowing policy is in addition to the Human Resource policy for handling employee grievance.
2- Aim and scope of the policy
The aim of this policy is to provide employees with a way to raise their concerns on any misconduct or wrongdoing while protecting them from reprisals, harassment, or victimisation for making any disclosure “whistle blowing” in good faith. It is intended to encourage and enable employees to raise their concerns irrespective of seniority, rank or status. It also ensures that employees receive feedback on any action taken.
This policy applies to all Haya Water employees, former employees, suppliers, customers and contractors engaged by the organisation. In this policy all of those personnel are referred to as “employees”.
3- What is considered as misconduct or wrongdoing?
The following types of activities or behaviours are considered to be misconduct or wrongdoing but not limited to:
- Unethical, illegal, or fraudulent act;
- Noncompliance with legal obligations and laws;
- Violation of policies and procedures;
- Accepting, requesting or approaching incentives from individuals either from within or outside the organisation;
- Undue favours to a contractor/vendor;
- Harassment, victimization, discrimination and bullying;
- Jeopardize the health and safety of individuals;
- Harmful acts to the environment;
- Deliberate manipulation of financial information and/or misrepresentation of financial statements.
4- Whistle blowing reporting channel
Depending on the situations it may be difficult for an employee to report any misconduct through the normal reporting channels. Therefore, we have created a specific “whistleblower reporting channel” for employees to raise their concerns. The whistleblower reporting channel is operated by independent professionals from the Internal Audit Department. The channel offers some specific protections as compared to the normal reporting channels such as the ability to raise a concern anonymously and maintain anonymity of individuals through the investigation process.
The whistleblower reporting channel should be used when:
- The whistleblowers believe that they will suffer as a result of raising their concern through the normal reporting channels;
- The normal reporting channels have been used and the concern remains unresolved;
- Inquire and discuss through an anonymous conversation on the best way to raise your concern.
Concerns may be raised face to face, by telephone, via email, or in writing to following address:
Chief Internal Auditor
P.O Box 1047
P.C 133 Al Khuwair
Muscat, Sultanate of Oman
4.1 Whistleblowing email
The whistleblower email address is email@example.com
4.2 Whistleblowing hotline
The whistleblower hotline contact numbers are:
- Calls made within the Sultanate of Oman – 800 711 00 (Toll Free)
- Calls made from all other countries – 00 968 800 711 00 (International rates apply)
The whistleblower will be given a reference number in which they can monitor the progress of the investigation and communicate anonymously. It is vital to maintain the reference number for communication purpose.
Haya Water recognises that raising any concern can be a difficult task because of fear of retaliation from those responsible for any misconduct or wrongdoing. Therefore, it will take all necessary measures to protect employees who raise a concern in good faith from any harassment or victimization as a result of raising a concern. Disciplinary action will be taken against employees that cause the whistleblower any disadvantage which may include termination of employment.
The employee’s identity that raises a concern will be protected by the organisation if they wish not to disclose it. However, there may be some circumstances such as legal proceedings in which it is necessary to disclose the whistleblower identity. When such cases occur then the identity of the whistleblower will not be revealed without discussing the matter with the concerned employee. If it is necessary for the whistleblowers to participate in the investigation, their identity will be kept confidential as reasonably possible and necessary actions will be taken in order to protect them.
7- Anonymous allegations
Employees who raise a concern are encouraged to provide their names and contact information so that the issues can be resolved quickly. It is the decision of the employees whether to identify themselves when raising a concern or keep their identity anonymous. However, if employees decide to keep their identity anonymous it might hinder the investigation or bring it to a halt. Anonymous allegations are more complex to act upon as there may not be enough evidence to substantiate the allegations. Obtaining further information from the whistleblower and provide feedback on the progress of the investigation will not be possible.
8- Untrue allegations
All concerns/allegations must be raised in good faith. If employees raise malicious or untrue allegations, disciplinary action may be taken against them. Employees do not need to be certain if any misconduct or wrongdoing is being performed. However, only genuine concerns on reasonable grounds should be reported.
9- Investigation process
Haya Water will ensure that the necessary resources are assigned when investigating any raised concern. If the whistleblower has any personal interest in the matter raised, it must be disclosed up front. All raised concerns will be taken seriously and the following procedure will be used:
1. A suitable individual will be identified to manage the raised concern. This individual will be in a position to take any necessary action as an outcome.
2. There will be an initial assessment by the Chief Internal Auditor to determine whether there are reasonable grounds for conducting a detailed investigation or whether the information provided is invalid. Some concerns may be resolved by agreed action without the need for an investigation.
3. If an investigation is required, then a suitable individual will be instructed by Chief Internal Auditor to conduct a thorough investigation into the raised concern.
4. The investigation will be initiated within a maximum of two weeks from the date of disclosure. The length and scope of the investigation will vary depending on the precise nature of the disclosure being investigated.
5. The whistleblower will be contacted and provided with the following information:
- Acknowledgement that the concern has been received;
- Indication of how the raised concerns will be dealt with;
- Inform whether a thorough investigation is needed or not;
- Estimated time required to reach the final outcome. The time period might vary depending on the nature of the investigation.
Depending on the nature of the investigation, the whistleblower might be requested to provide further information.
10- Outcome of the investigation
The following are possible outcomes of the investigation:
- If the outcome of the investigation established that misconduct has occurred, appropriate action will be taken against the person who committed the misconduct.
- If the misconduct has resulted in any criminal or fraudulent act then this may involve reporting the matter to relevant external authorities such as Royal Oman Police and Public Prosecution. In such cases, the whistleblower might be required to give evidence in criminal or disciplinary proceedings, the organization will advice about the procedure and provide any support needed.
- If there are no sufficient evidence confirming any misconduct, or the actions taken by the individuals are not serious enough to warrant any disciplinary action against them, informal approach might be taken to deal with the matter.
Once the investigation is complete, an investigation report will be issued and the whistleblower will be contacted directly to communicate the outcome of the investigation. However, the details or a copy of the report will not be given to the whistleblower.
The investigator might propose some recommendations for change to enable the organisation to minimise the risk of recurrence or ensure that the misconduct will not arise again which has been discovered as part of the investigation. The Chief Internal Auditor and Audit Committee will be responsible for reviewing these recommendations, identifying implementation owner, and implementation date for every recommendation. These recommendations for change will not be communicated to the whistleblower.
11- Communication strategy
This whistle blowing policy will be communicated through the following means:
- Published on the Haya Water portal
- Published on Haya Water’s website
- It will be communicated to new employees and contractors and suppliers;
- Fliers will be developed and placed across the organization;
- Roadshow presentations.
12- Policy review and update
To ensure the effectiveness of this policy, it is monitored and reviewed annually or whenever needed by the Chief Internal Auditor. A record of concerns raised will be retained and reported quarterly to the Audit Committee.
Learning from these incidents will be shared with the company management and Audit Committee.