HIGHLANDS CANNERS HIG HL ANDS CANNERS LTD

LIMITED
Issue
Document: Document Title: Date of Issue /Rev. No.
PROCEDURES WHISTLE BLOWING 14.10.2021
MANUAL
Ref. No: Prepared By: Approved By: Page:
Page 1 of 3

HR -1-07
HUMAN RESOURCE MANAGING
MANAGER DIRECTOR

Purpose
References
Definitions
Responsibility and Authority
Detail of Procedure
Annexes

1. SCOPE
This procedure covers the process of handling whistle blowing.

2. PURPOSE

To ensure adequate control in management of whistle blowing.

3. REFERENCES

3.1 Human resources policies manual

3.2 Management of whistle blowing Procedure
3.3 Employment Act, 2007
3.4 The Labour Relations Act, 2007
3.5 The Occupation Safety and Health Act,2007
4. DEFINITIONS/ABBREVIATIONS

4.1 HR-Human Resource

4.2 HRM-Human resource manager.
5. RESPONSIBILITY AND AUTHORITY

5.1 Human Resource Manager

 To provide advice as to how best to handle situations involving
employees
 Enabling quick decision making
  HIG HL ANDS CANNERS LTD Responsible for development

and implementation of services designed to support affected employees

during and after incident.
 Ensures temporary staffing, benefit issue or bringing in grief
counselors.
6.DETAIL OF PROCEDURE

Stage 1: -Disclosure

You should normally raise concerns either verbally or in writing without immediate
supervisor/manager but depending on the seriousness and sensitivity of the issues involved and
who is suspected of the malpractice, you may contact the HR manager or the chief executive
directly. We encourage employees to disclose their identity in confidence since it may not be
possible to keep an anonymous whistleblower informed of decisions and progress of
investigations, or to ensure their protection as per the Company Policy. We may also need
clarifications and consultation during investigation so that we can prefer the most appropriate
disciplinary action in a justifiable manner. All disclosed information in this manner will be
treated as protected information. The company disregards anonymous letters/emails/text
messages and shall not take cognizance of such approaches.

Stage 2: -Investigation

After receiving the information, the HR manager, or the management Rep in receipt of the
information shall carefully and professionally scrutinize the information given to check whether
the information fulfills the requirement to be considered as protected information.

 If it is protected information, the whistle blower will be advised of the next steps in the
process
 If it is not a protected disclosure but was made in good faith, the whistle blower will be
advised on the procedures that might be used to complain and, on the right, to appeal to
the hr. manager in case of any dissatisfaction.
 Once information has been considered as protected information, the HR manager, or the
management rep in receipt of this information shall determine the sensitivity of the
information and in consultation with the Chief Executive Officer decide on the best next
step.
 If more information is needed, the management rep may question the whistleblower
further
 At this stage and if further investigations are required, the police may be involved.

Stage 3: -Unacceptable behavior

 The Company shall consider HIG HL ANDS CANNERS LTD
the following offences as

Gross Misconduct which attracts substantial penalties including summary dismissal:

1. To take or threaten to take revenge against a whistleblower

2. To breach confidentiality
3. To knowingly provide false information
4. To obstruct or behave in a manner likely to obstruct the investigator.

NB: The Board of Directors may occasionally approve a token towards whistle blowers

6. RECORDS
6.1 Master List of records
6.2 Whistle blowing records

7. REVISIONS HISTORY

REVISION REVISED
NUMBER PAGE(S) DESCRIPTION DATE