REPORTING & WHISTLEBLOWING
Speaking up is crucial to our culture and our long-term results—it is a living example of our values. Speaking up when something doesn’t seem right demonstrates our integrity and that we have the courage to do the right thing. It aids to prevent mistakes and misconduct and foster innovation. Furthermore, it displays that we care about each other and our business.
Any person who becomes aware of a breach or suspected breach of this Code should report it to their manager and the Risk, Compliance and Governance Officer or to a member of the Executive Team. They will investigate and where necessary act on the report.
Oryx will support any person who, in good faith, reports a breach or suspected breach of this document. Oryx will, subject to any legal requirements, keep confidential the identity of a person making a bona fide report.
In being true to the values of integrity and care—if you report a concern, it will be handled with appropriate confidentiality and discussed with others only as needed or advisable under the circumstances. Exercising professional scepticism, applying common sense, and knowing and applying the contents of this document as well as the local supplementary guidance, will help each of us know when to speak up through whichever channel we are most comfortable.
Where relevant, you must co-operate with assessment and management of fraud incidents.
The Executive Team will assess the situation, recommend a course of action and develop a management plan in consultation confidentially with Human Resources, and the line Manager Employees should provide all relevant information to assist with the assessment where possible.
The Risk Officer will record all reports of suspected contravention of this document, including evidence available to support the allegation. The Risk, Audit and Compliance Committee and Remuneration Nomination Sustainability and Ethics Committee will be notified of the existence of such reports.
The Company will use its best efforts to protect whistle-blowers against retaliation. Whistleblowing complaints will be handled with sensitivity, discretion, and confidentiality to the extent allowed by the circumstances and the law. Generally, this means that whistle-blower complaints will only be shared with those who have a need to know so that the Company can conduct an effective investigation, determine what action to take based on the results of any such investigation, and in appropriate cases, with law enforcement personnel. Should disciplinary or legal action be taken against a person or persons as a result of a whistle-blower complaint, such persons may also have the right to know the identity of the whistle-blower.
As far as is possible and subject to legal and regulatory obligations, Oryx will endeavour to maintain the confidentiality of Employees in order to protect those people from reprisals or victimisation. There may be circumstances where the law enforcement agencies or regulators will be notified of the fraudulent conduct.
In some situations, the nature of the breach or its proper investigation may lead to the identity of the reporter becoming suspected or require his or her identity to be disclosed. In the latter case, Oryx will discuss the situation with the reporter before disclosing his or her identity.