NPS MedicineWise will investigate all matters reported under this Policy as soon as practicable after a matter has been reported. The relevant Whistleblower Governance Officer will conduct a summary assessment and if necessary appoint an internal or external investigator to assist in conducting the investigation.
All investigations will be conducted in a fair, independent and timely manner and all reasonable efforts will be made to preserve confidentiality during the investigation.
5.1 Investigation process
A Whistleblower’s report may only be investigated and acted upon following referral to a Whistleblower Governance Officer. Any other person (such as a manager) who receives a report of a Reportable Conduct must immediately refer it to a Whistleblower Governance Officer, take no further action and keep the report confidential
If the report is not anonymous, the Whistleblower Governance Officer or external investigator will contact the discloser to discuss the investigation process and any other matters relevant to the investigation.
The Whistleblower Governance Officer is appointed to:
Safeguard the interests of the Whistleblower,
Assess the immediate welfare and protection needs of a Whistleblower and, where the Whistleblower is an employee, seek to foster a supportive work environment,
Respond as appropriate and necessary to any concerns or reports of victimisation by a Whistleblower.
If the discloser has chosen to remain anonymous, the identity will not be disclosed to the investigator or to any other person and NPS MedicineWise will conduct the investigation base on the information provided.
Where possible, the Whistleblower Governance Officer will provide the discloser with feedback on the progress and expected timeframes of the investigation.
Details of the steps that NPS MedicineWise will take upon receipt of a disclosure, including the support available to a person making a disclosure, are set out in the ‘Manage Whistleblower Incident’ on Promapp.
5.2 Investigation Outcomes
The role of the Investigator is outlined in Appendix A
In summary, he or she is required to:
Investigate the matters referred to in the disclosure in a timely manner;
As soon as reasonably practicable, provide an investigation report to the Whistleblower Governance Officer which should include a description of the steps taken, findings of fact (judged on the balance of probabilities), recommendations for appropriate action.
Following the receipt of the report from the Investigator, the Whistleblower Governance Officer is required to consider the report from the Investigator and to ensure appropriate steps (if required) are taken to address matters referred to in the disclosure and to communicate the outcome to the Whistleblower.
The Whistleblowing Governance Officer will decide whether or not the person named in the allegation should be informed that a suspicion was raised and found to be baseless. This decision will be based on a desire to preserve the integrity of a person so named, so as to enable workplace culture to continue unfettered and to protect the Whistleblower.
Where an investigation does not substantiate the report, the fact that the investigation has been carried out, the results of the investigation and the identity of the person who is the subject of the report must be handled confidentially.
Generally, where an investigation is conducted and the investigator believes there may be a case for an individual to respond, the Investigator must ensure that a person who is the subject of a Whistleblower disclosure:
Is informed of the substance of the allegations;
Is given a fair and reasonable opportunity to answer the allegations before the investigation is finalised;
Has their response set out fairly in the Investigator’s report; and
Is informed about the substance of any conclusions (adverse or otherwise) in the investigator’s report that affects them.
Where adverse conclusions are made in an investigator’s report about an individual, that individual has a right to respond to those conclusions prior to any action being taken by NPS MedicineWise against them.
To the extent permitted by law, the Whistleblower Governance Officer may inform the discloser and/or the person against whom allegations have been made of the findings. Any report will remain the property of NPS MedicineWise.
The Whistleblower Governance Officer is also required to communicate to the Whistleblower the way in which NPS MedicineWise will monitor to ensure the Whistleblower is not unfairly treated because of the disclosure.
5.3 Record Keeping
NPS MedicineWise will establish and maintain records of all reports of Reportable Conduct received, the investigation process undertaken, and any actions taken to resolve the matter. Reasonable efforts will be mad to preserve the confidentiality of recorded information.