Whistleblowing Policy and Procedure

Policy number: NA

Version: 1.0

Approved by: Dr. Matthew Morell,  Director General 

Policy Owner: Head - Human Resources and Organizational Development (HR OD)

Effective date: July 2019

Review Date: 2024  - Update Required

To view the approved/signed version of this document, please click the button below. Where the interpretation of this policy is in question, the original document must be used.

Whistleblowing Policy and Procedure

PROCEDURE

1. PURPOSE

   Whistleblowing procedures outlined here are intended to give practical application to the spirit and letter of the policy. This procedure may occasionally be revised to reflect local contexts or structural changes.

2. APPICATION

   The whistleblowing process applies in three ways:

   1. Raising concerns internally within IRRI.

   2. Raising concerns externally outside IRRI

   3. How IRRI will deal with the concerns raised.

3. EXCLUSIONS

   1. If staff raising a concern wish to make a complaint about employment or personal grievance, bullying harassment issues which are not directly connected with the ethical wellbeing of the organization, the grievance or bullying /harassment policy should be used. 

   2. If the concern is about misuse of funds, the IRRI code of conduct (misuse of funds policy) should be used in the first instance.

4. PROCEDURS

   Raising Concerns within IRRI

   Step 1:

   IRRI staff who become aware of any criminal wrongdoing on the part of colleagues, senior officers or others, or who have serious concerns about malpractice, theft or fraud which might adversely affect IRRI’s business or reputation, or might otherwise put at risk the health or safety of anyone, should first raise it in confidence with their immediate supervisor/line manager/team leader in writing immediately.

   In more serious cases or if the allegation is about the actions of their immediate supervisor/line manager, individuals should feel able to raise the issue with a more senior manager, bypassing lower levels of management or directly raising with one of the ‘Named Persons’ set out in this procedure. If raised with the more senior manager they can liaise with any one of the ‘named persons’ in this procedure.

   Step 2: Revision Required

   The method of disclosure: This could initially be verbal, however, it is expected that whistleblowing disclosures are in writing (a letter/email/memo) sent to one of the following ‘Named Persons’ or their designees.

   Named Persons Ola Fajobi
   Director HR & OD
   Email: o.fajobi@irri.org
   Phone: +63 (2) 580-5600 ext 2742 , Mobile: +63(917) 820 6848

   or

   Angshu Sengupta
   Director of Finance
   Email: a.sengupta@irri.org
   Phone: +63 (2) 580-5600 ext 2549 Mobile: +63(917) 8544794

   or

   Jacqueline d’A Hughes
   Deputy Director General (Research)
   Email: j.hughes@irri.org

   If the individual raising the concern believes there are outstanding/unresolved issues, the issue involves staff at Director level or that there has been unreasonable delay in handling or addressing the concern they have raised they can contact the Director General or the named Trustee setting out in writing what they believe outstanding or unresolved issues are:

   Matthew Morell
   Chair of Audit Committee Director General
   Email: m.morell@irri.org

   Jim Godfrey
   Chair IRRI Board of Trustees
   Email: Jim.Godfrey@godfrey.uk.com

   If the whistleblowing relates to concerns in IRRI’s international country offices, these can be raised through country based ‘Named Officers’ below or via the ethics hotline.

   Rashmi Dhamija
   Corporate Services Manager (India Office)
   Email: r.dhamija@irri.org

   Elizabeth Ali
   Corporate Services Manager (Bangladesh)
   Email: e.ali@irri.org

   Alexandre Lucas
   Corporate Services Manager (Kenya Office)
   Email: a.lucas@irri.org

   Raising Concerns outside of IRRI Confidentially (Ethics Hotline)

   1. A key aspect of IRRI’s commitment to management practices and work processes that nurtures high levels of integrity, ethical and moral conduct of our workforce, individuals can raise concerns via Lighthouse (an ethics reporting hotline) staffed by an independent and impartial third-party.

   2. The option to report to a confidential hotline assists with the early detection of unethical practices and encourages staff to make a protected disclosure 24/7 as well as circumstances where the individual wishes to be anonymous.

   3. Individuals making disclosures employee will have access to a multilingual reporting hotline 24 hours a day, seven days a week. This means that a report can easily be filed outside of normal working hours. In addition to a toll-free hotline available in IRRI country office locations the toll- free line is available from almost anywhere globally, so the individual making disclosures can submit a report via alternative methods like email, or the internet.

   4. If the report is made via the ethics hotline, a ‘named person’ (or an investigator assigned by them) manages the disclosure as outlined in section 5 below.

   5. Details of the ethics reporting hotline are as below:

      Lighthouse Services Inc.
      www.Lighthouse-Services.com

    

   Ethics Hotline Service

   1. Staff members may choose to submit anonymous concerns by using the ethics hotline. The ethics hotline is run by an independent third-party provider and is designed to protect the staff member’s confidentiality and anonymity, if requested.

   2. The hotline administrator does not record the telephone number of persons calling the hotline or retain the IP address or other identifying information of reports made via the website. The hotline provider will make every effort to protect the reporter’s identity but anonymity cannot be guaranteed.

   3. The information provided in a hotline report may be the basis of a confidential internal and/or external investigation into the issue being reported and the staff member’s identity may become known during the course of an investigation because of the information provided. Reports to the hotline, including the identity of the reporter, will remain confidential to the extent reasonably possible.

   4. The hotline operates 24 hours a day, seven days a week and provides a web-based reporting capability as well as email, fax and a toll-free telephone-based service.

   5. To access the ethics hotline via the web, visit https://www.lighthouse-services.com/irri. To access the ethics hotline via the telephone, dial 833-210-0002. (Non-US callers, click here details are pending contract commencement in July 2019 for international dialing instructions.). To send a report via email, use the email address reports@lighthouse-services.com. To send a report via fax, dial (215) 689-3885.

   6. The hotline administrator who answers a call to the hotline will document the date, time, and duration of the call and collect pertinent information about the issue or request provided by the caller. This generally includes the names and titles (with correct spellings) of the persons involved in the issue being reported, when and where the issue occurred, information about the frequency of occurrence, how the caller learned of the issue, the existence of any documentation that would be useful in reviewing the issue, other persons aware of or notified about the issue, any steps taken to address the issue, and any other information that would be helpful to understanding and investigating the issue.

   7. This information is compiled into a call report, which is assigned a report identification number. The report identification number will be provided to the caller and the call report, including that number will be sent to the Director of Human Resources and Organizational Development.

   8. For reports submitted through the website, the reporter will input the requested information (similar to that requested for telephone submissions) and receive a report identification number. The hotline administrator will send reports received through the hotline website to the Director of Human Resources and Organizational Development.

   9. For whistleblowing concerns related to conduct in the HR & Organizational Development function these should be raised with the Director General as the Named Person.

5. HOW IRRI WILL HANDLE WHISTLEBLOWING CONCERNS RAISED

   1. Issues of concerns & disclosure will (wherever possible) be acknowledged within 5 working days.

   2. Once a concern has been received directly or externally via the ethics hotline, it will be assessed and considered with regards to appropriate action to be taken. The named person who has been contacted will make every effort to deal with such disclosure in a fair & objective manner by either investigating the matter as quickly as possible or nominating an appropriate person to carry out an investigation.

   3. The investigation may involve an informal review, an internal inquiry or a more formal investigation. IRRI will inform the whistle blower of the individual who will be handling the matter, how they can be contacted and what further assistance (if any) may be required of the whistleblower.

   4. On completion of the investigation the named person will make recommendations on the appropriate course of action to the Director General /Chair of the Board (via the Director General) who will make the final decision. There is no right of appeal against the outcome/decision made under the whistleblowing policy. The exception to this is in circumstances where there remains outstanding/unresolved issues or that there has been protracted delay in handling or addressing the concern. Such appeals should be directly addressed to the Director General/ Chair of the Audit Committee or Chair of the IRRI Board of Trustees.

   5. The outcome and decisions resulting from the whistleblowing action may trigger the use of other IRRI processes that require further action. For example if the concern falls more properly within the grievance, bullying and harassment or other relevant procedures. The individual raising the concern will be informed of this where appropriate.

6. PROCEDURES FOR HANDLING COMPLAINTS TO THE ETHICS HOTLINE

   The Director of Human Resources & Organizational Development (or an appropriately confidentiality vetted designate) will review reports and determine the appropriate next steps for investigating the matter.

   1. If the report relates to a staff member’s concern about an area unrelated to (1) an alleged violation of law or (2) business ethics and conduct, such as a question about benefits or compensation, the Director of Human Resources & Organizational Development will forward the report to the appropriate department.

   2. In some instances, the caller may want to follow-up on their report to determine the outcome of their initial report. Callers may contact the hotline and provide the report identification number assigned to their initial report. The hotline administrator will advise the caller about the status of their report.

   3. For reports submitted through the hotline website, reporters may follow-up through the website or by telephone for an update and reference the report identification number that was assigned when the initial report was submitted.

   4. Whether submitted by telephone or website, the Director of Human Resources & Organizational Development may determine that additional information would be helpful or is necessary for a thorough investigation of the report. In those instances, the Director of Human Resources and Organizational Development may request additional information from the reporter by leaving such a request with the hotline administrator.

   5. Upon resolution of the issues raised in the report, the Director of Human Resources and Organizational Development will notify the hotline administrator that the report has been resolved and the case is closed.

   6. Records pertaining to each report, the investigation, if any, and the disposition of the issue reported will be retained in accordance with IRRI’s record retention policy. The Director of Human Resources, or his or her designee, is also responsible for ensuring that such records are maintained in a secure location in order to protect confidential information.

7. INVESTIGATION PROCESS

   Whistleblowing investigations will be conducted in accordance with IRRI’s established practice and approach to investigations except where there are valid reasons to deviate from this for example to ensure the integrity of the wider whistle blowing process or the protection of the whistleblower.

   The investigation process and procedure will typically require:

   Preliminary Enquiry

   1. All complaints received are to be recorded and looked into “prima-facie” through a preliminary investigation.

   2. If preliminary inquiry indicates that the disclosure complaint has no merit/basis, or it is not a matter to be pursued under this policy, it may be dismissed by a formal communication in writing.

   3. Any of the ‘Named Officers’ may at their discretion, appoint a designated third party investigator during preliminary enquiry.

   Full Investigation

   1. Where preliminary enquiry indicates that further investigation is necessary, this will be carried out either by the ‘named person’, or their designated investigator(s).

   2. All Investigations must be conducted fairly, as a neutral fact finding process and without presumption of guilt.

   3. In the event of a full investigation, the investigator is required to prepare a written report on the findings.

   4. The investigation shall be completed as soon as possible and normally within 30 days of the receipt of the protected disclosure. This period is extendable as reasonable and necessary in individual circumstances by such period as the ‘named person’ deems fit.

8. Roles & Responsibilities

   All staff managers and directors have a responsibility to promptly report any breach of IRRI’s Code of Conduct, values or subject matter areas covered under the whistleblowing policy. Roles and responsibilities of individuals involved the whistle blowing process are set out below.

   Whistleblower

   1. To report upon notice or being aware of, immediately improper practice, unethical behavior and/or actual or suspected fraud etc.

   2. Cooperate with investigating authorities, maintain full confidentiality.

   3. Seek full protection from retaliation/retribution. However, this does not extend to immunity for the whistleblower’s involvement in the matters that are subject of investigation.

   4. In exceptional cases, where the whistle blower in good faith believes that there remains outstanding/unresolved issues or that there continues to be unreasonable and protracted delay in handling or addressing the concern, they can directly appeal to the Director General or the Chair of the Audit Committee.

   Named Person /Designated Investigator 

   1. Ensure that the policy is properly implemented.

   2. Acknowledge receipt of complaint to the whistleblower.

   3. Record the initial enquiry.

   4. Ascertain prima facie the credibility of allegation/disclosure. If initial enquiry indicates further investigation is not required, close the issue.

   5. Ensure complete fact finding and conduct the enquiry in a fair and unbiased manner. F. Maintain strict confidentiality.

   6. Ensure that necessary safeguards are provided to the whistleblower.

   7. Determine facts and probabilities in the outcome of investigation and identify any/all violations committed and if so by whom.

   8. Recommend appropriate course of action.

   9. If sanctions such as suggested disciplinary actions (preventive measures and dismissals) are likely to be recommended the advice of the Director of Human Resources should be sought before finalizing recommendations.

   Person(s) Subject to Investigation 

   1. Provide full cooperation to the investigation team.

   2. Be informed of the outcome of the investigation. 

   3. Accept the decision of the Director General/ Chair of Audit Committee. D. Maintain strict confidentiality.

   Director General /Chair of the Board Audit Committee

   1. In situations where the Whistleblower directly approaches the Director General /Chair of the Audit Committee, either will refer the matter to the director level ‘named person’ in the policy or the designated investigator appointed by the named person.

   2. In the event that there is a conflict of interest in such complaint, the Director General will in consultation with the Director of HR & OD entrust the investigation to some other Officer (as appropriate) to investigate the matter as per the procedure above.

   3. If the Chair of the Audit Committee has a conflict of interest on the issue, the matter should be referred to the Chair of the Board of Trustees for resolution.

   4. After the Director General /Chair of the Audit Committee is provided with the investigation report recommendations, they are expected to reach a decision on and proceed with appropriate disciplinary action as established in IRRI’s disciplinary policy and procedure in consultation with the Director of HR & OD.

   5. The decision of Director General/ Chair of the Audit Committee shall be final and binding except in cases where the matter was referred to the Chair of the Board, where the decision of the Board of Trustees’ Chair will be final and binding.

9. WHISTLEBLOWING GUIDELINES

   1. IRRI encourages individuals reporting whistleblowing concerns not to report such concerns anonymously unless they believe that it is essential to do so . However, if the individual has a genuinely held fear that they might face reprisals as a direct result of reporting their concerns they should avail of the independent external reporting facility (ethics hotline) that IRRI provides.

   2. Individuals raising a whistleblowing concern are encouraged to indicate how they believe the matter might best be resolved. While that may be obvious in many scenarios, this is not always the case.

   3. The whistleblower should always declare any personal interest they have in the matter.

   4. A whistleblower is protected under IRRI’s Whistleblowing policy when using IRRI approved reporting channels. A whistleblower who uses improper avenues (for example via external media/ social networking to raise concerns may lose their protection for anonymity, unfair treatment and unfair dismissal.

   5. Whenever possible, and subject to legal constraints the whistle blower will be informed of the final outcome of investigations relating to the concerns they have raised. IRRI may not be able to divulge details of precise actions taken where this would infringe duties of confidentiality IRRI owes to other parties. Following that the matter will be deemed closed in relation to the whistleblower.

10. FREQUENTLY ASKED QUESTIONS

    Q: What is whistleblowing?

    A: Whistleblowing is broadly defined as raising a concern or alarm in good faith on the basis of prima facie information the whistleblower has. Whistleblowing also covers the deliberate, voluntary disclosure of any suspected or anticipated misconduct within the Institute that is normally within its ability to control.

    Q: What is IRRI’s whistleblower policy?

    A: IRRI’s whistleblower policy reflects the Institute’s commitment to open and transparent corporate governance by creating channels staff can report conduct which is damaging to the interest of the Institute through a mechanism that also protects them from risk of subsequent retaliation.

    Q: Why did IRRI develop this policy?

    A: IRRI developed this policy to as part of its encouragement of staff engagement and open ongoing channels of communications so that staff members can report any violation of the Code of Conduct and other Institute policies. The policy also ensures that due process is respected by investigating reported infractions and appropriately addressing these.

    Q: What does the term whistleblower mean?

    A: The term “whistleblower” is a common global terminology for a person who exposes a wrong-doing, as well as a potential wrong-doing especially within an organization. It also refers to any staff member, director, consultant, partner organization, who makes a protected disclosure, with the intent of safeguarding IRRI organizational interests.

    Q: Can anyone be a whistleblower?

    A: Yes. All staff members working for the Institute, regardless of their position, type of employment, or location can be a whistle-blower.

    Q: What kinds of concerns or wrongdoing can I report? 

    A: Alleged wrongdoing is reportable when it occurs or is likely to occur, and may either be an act, or a failure to act. Staff can report concerns or complaints regarding conduct by IRRI Board and staff members which they seriously consider:

    1. Is a breach of, or failure to implement or comply with the Institute’s governing rules, procedures, policies, or established standards of practice, e.g. accounting, supply chain, human resources;

    2. Is illegal (e.g. fraud)

    3. Is unethical or inconsistent with the standards to which the Institute subscribes; d. Is, or will result in, a waste resources, or poses a risk to the Institute’s reputation and integrity;

    4. Represents scientific fraud (e.g. data falsification, plagiarism) or ethical violation (e.g. regarding use of data, authorship, rights);

    5. Is a dangerous practice likely to cause harm or damage to persons or property; g. Is an abuse of power or authority;

    6. Constitutes discrimination in the course of employment or in the provision of services;

    7. Represents a conflict of interest;

    8. Is an attempt to deliberately conceal any of the above acts or omissions.

    Q: Who should I direct and report my concerns to?

    A: There are two channels for internally reporting misconduct. Whistleblowers are encouraged to convey their concern verbally or in writing to their immediate supervisor in the first instance. Subsequent to that or if that is not appropriate, they should contact one of the following ‘named persons’ in the procedure:

    1. Director of Human Resources & Organizational Development

    2. Director General

    3. Director of Finance

    4. Deputy Director General (Research)

    5. Chief of Staff

    6. Corporate Services Managers (Country based)

    7. The Chair of IRRI’s Audit Committee/ Chair IRRI Board of Trustees

    Alternatively, staff can report concerns via the external ethics hotline. The hotline is run by an independent third-party provider and is designed to protect the staff member’s confidentiality and anonymity, if requested

    Q: What happens after I file my whistleblower report?

    A: The ‘named person’ who is the recipient of the whistleblower report will act immediately on any disclosure. Once the disclosure is received, an initial assessment and preliminary inquiry will be conducted to determine what action should be taken. If the concern is determined to fall within the whistleblower policy, an initial inquiry will be undertaken by the named person (or designee) to decide whether a formal investigation is appropriate.

    Urgent action if necessary may also be taken before any investigation is conducted, on completion of the investigation, the recipient of the disclosure will prepare a report which determines the existence or otherwise of misconduct, and presents recommendations to the Director General (via the Director of HR and OD) on appropriate action.

    Q: Will I be informed of the outcome of my reporting of misconduct concerns?

    A: Yes. IRRI acknowledges the right of the whistleblower to receive confirmation that the act or omission reported has been properly addressed. The whistleblower will be given as much feedback as appropriate in the circumstances. Subject to legal constraints, the whistleblower will be informed of the final outcome of the process.

    Q: If I think that my concerns cannot be properly addressed by the management, is there a reporting mechanism to the Board?

    A: There are no specific mechanisms for reporting concerns to the Board. Any such concerns should be set out in writing to the Chair of the Audit Committee (via the Director General)

    Q: Will my whistleblower concerns and report be held in confidence?

    A: Yes. IRRI will respect and protect the confidentiality discharging their duty in good faith as is appropriate and necessary of staff.

    Q: If I do not want to be identified, can I just make an anonymous report?

    A: IRRI encourages staff to ideally provide as full as possible details often including their name and contact details as all allegations need to be fully looked into and this facilitates the investigation of the matter that has been raised. In addition, whistleblowers are protected from retaliation or reprisals. However, staff have the option to confidentially report their concerns confidentially using the independent Ethics hotline.

    Q: If I am involved in a wrongdoing / misconduct will reporting it exempt me from penalty?

    A: No. The whistleblower policy will not shield whistleblowers from reasonable consequences flowing from any involvement in misconduct. A staff member’s liability for his/her own conduct is not affected by his/her disclosure of that conduct. However, in some circumstances, an admission may be a mitigating factor when considering disciplinary or other action.