Optus Employee Conduct and Whistleblower Policy

Integrity is one of our core values and we are committed to conducting business to the highest standards of corporate governance and accountability.  We set these out in our Code of Conduct, which provides clear direction on how we expect our people to act and conduct themselves, and by providing ways to report suspected misconduct, including through our whistleblower process.

Our Code of Conduct

The Optus Code of Conduct applies to all our people.  It sets out principles to guide them in carrying out their duties and responsibilities when dealing with colleagues, competitors, customers, suppliers and the community. The Code of Conduct covers areas such as business and workplace behaviour, protection of Optus assets, information and intellectual property, maintaining confidentiality, managing conflicts of interest, and our zero tolerance to fraud.

The Code complements our people’s wider obligations to comply with applicable laws and regulations that apply to Optus.  Employees that breach the Code of Conduct will be subject to disciplinary procedures.

Zero tolerance towards fraud

Optus adopts a “zero tolerance” approach to fraud, corruption and other forms of unethical behaviour or conduct.  Concerns about suspected fraudulent or unethical conduct can be reported to Optus through a range of channels, including through our Whistleblower Hotline, which can be used by employees, customers, suppliers and business partners.

Investigations of suspected fraud, corruption or unethical conduct will be carried out in an objective manner, regardless of the person’s length of service, position, or relationship to Optus. If the investigation confirms that the person’s actions were criminal, we will refer the case to the Police or another law enforcement agency.  Any employees found to have engaged in fraud or other forms of unethical conduct by an investigation will be subject to disciplinary procedures.

Whistleblower Policy

The Optus Whistleblower process is covered by the Whistleblower Policy.  This Policy clearly sets out the channels where employees and external parties can, in confidence, raise concerns about suspected fraud, corruption, misconduct and/or other wrongdoing without fear of reprisals. The Policy identifies the parties authorised to receive complaints, including details of the direct reporting channels to Internal Audit and Optus Whistleblower Hotline service, which is independently managed by an external service provider.

The Policy’s key features are:

• Whistleblowers are encouraged to report their concerns if they have reasonable grounds for suspicion
• Employees and other persons making reports will be treated fairly and, to the extent possible, protected from reprisal, retaliation, and detrimental conduct.
• Whistleblowers can report matters anonymously, but if they choose to disclose their identity, the Policy requires confidentiality to be maintained at all times to protect their identity.
• All complaints will be investigated in an objective manner by an independent team that has appropriate skills and knowledge, following a structured process to ensure proper conduct of investigations.
• The outcome of each whistleblower investigation and the follow-up actions taken are reported to the Singtel Board Audit Committee (the AC).
• The adequacy of the Whistleblower Policy and the underlying processes are reviewed annually and reported to the AC for review and approval. The review includes identifying changes to keep our Whistleblower Policy in line with best practices and ongoing compliance with any regulatory requirements.

The Policy is promoted during Optus training and through periodic communication to all Optus people as part of our efforts to promote strong ethical values and fraud and control awareness

Optus recognises there will be times when a person makes a report based on reasonable grounds for suspicion which later proves to be unsubstantiated. However, the organisation will take action against those who intentionally or maliciously give false or misleading information against someone else.

Further details on how to contact the Whistleblower Hotline for Optus can be found here.