Minor Hotels Australia and New Zealand (Minor Hotels) is committed to a culture of compliance that is grounded in honesty, trust, and personal accountability. We firmly believe that raising concerns is a positive act that can make a valuable contribution to improving our long-term success. On this page you will find resources and link to an online form that will help you to raise concerns regarding ethics and wrongdoings within Minor Hotels.
We adopted a Whistleblower Policy that explain the processes for reporting the wrongdoing, including what happens when you make a report and establishes a protection framework, so anyone can speak up without fear of reprisal or retaliation.
- 1. What is Whistleblowing?
Whistleblowing is the process during which you are encouraged to report wrongdoing within Minor Hotels Australasia through a formal and confidential channel.
- 2. Why should I report suspected misconduct?
Whistleblowing is important for fostering high ethical standards and thus maintaining customer and public confidence in an organisation and its operations. By blowing the whistle you can contribute to preventing the possible escalation of misconduct. Australia and New Zealand have whistleblowing laws that provide certain legal rights and protections to certain whistleblowers. See guidance from the ASIC here: Whistleblower rights and protections (for Australia) and from the Public Service Commission here: Protected Disclosures (Protection of Whistleblowers) Act 2022 (for New Zealand).
- 3. What wrong doing can be reported?
We want to hear from you if you suspect or witness any wrongdoing in the following matters:
(a) a breach of Minor Hotels Australasia’ policies and Code of Conduct;
(b) an offence under any regulation or law;
(c) illegal activity (including theft (cash or property), fraud, embezzlement, drug sale/use, violence or threatened violence and property damage), taxation infringements or an activity that poses a substantial risk to the environment;
(d) unethical, dishonest or corrupt behaviour or conduct, including soliciting, accepting or offering a bribe or kickback, manipulating systems or processes to receive financial benefits;
(e) behaviour or conduct that is detrimental to Minor Hotels Australasia’ reputation;
(f) behaviour or conduct that is detrimental to Minor Hotels Australasia’ financial position;
(g) behaviour or conduct that is endangering health or safety;
(h) conflicts of interest;
(i) an abuse of authority or concealment of wrongdoing;
(j) significant waste or substantial mismanagement of Minor Hotels Australasia’ resources;
(k) intentional concealment or misrepresentation of data, records, events or information;(l) falsification of financial records or transactions, including improper behaviour relating to accounting, internal accounting controls, actuarial, or audit matters including impeding internal or external audit processes.
- 4. Who can submit a report?
To be treated as a whistleblower under this Policy you must be:
(a) A current or former officer or employee of Minor Hotels Australasia;
(b) A contractor or supplier of goods and services to Minor Hotels Australasia, or their current or former employees;
(c) An associate of Minor Hotels Australasia (as the term associate is defined under the Corporations Act 2001); or
(d) A family member or dependent of an individual mentioned above.
- 5. What information should I include in my report?
To enable a thorough investigation, you should include a detailed description including what has happened, as well as when and where it happened. You do not have to have proof of your suspicions, but a report should always be submitted in good faith.
- 6. Do you accept anonymous reports?
We also accept anonymous reports. We will respect and protects your identity if you choose to make an anonymous report. You can choose to remain anonymous while making a report, interacting with the report recipient during an investigation process, as well as after the case is closed. Please note, Minor Hotels Australasia cannot provide you with any updates on your report if you remain anonymous.
- 7. Are reports confidential?
We are committed to ensuring the confidentiality of whistleblowers to ensure that a whistleblower disclosing information is not required to provide their identity or any details which may lead to their identification when making a report under our policies. If a whistleblower does choose to provide their identity when making a report, subject to exceptions (listed in our policy), Minor Hotels Australasia will take all reasonable steps to protect the identity of the whistleblower to maintain confidentiality in accordance with the law, unless the whistleblower consents to the disclosure of that information. Minor Hotels Australasia may need to disclose the contents of the report to in-house or external lawyers to obtain advice, the police, regulatory authorities, the tax office and other commonwealth bodies prescribed by legislation.
- 8. What if the report is untrue?
If a whistleblowing report was made in good faith, but the wrongdoing was not confirmed by the investigation, no action will be taken against the whistleblower. As much as we encourage honest reporting, we do not tolerate false reports. If a report was made with malicious intent or for personal gain, we reserve the right to take action against that particular individual.
- 9. What happens after you submit a report?
We want to be transparent and outline the investigation process of a report submitted through our whistleblowing channels. Below, you will find brief explanation of the investigation process:
- Receipt of the Report. When a report (anonymous or otherwise) is received, it will be forwarded to the Minor Hotels Australasia Senior Leadership Team.
- Evaluation. If the report has enough information, the Senior Leadership Team will perform an initial assessment to confirm that the report is a valid report, evaluate the case and adopt an investigation plan. For a report to be fully investigated, it must contain sufficient information to form a reasonable basis for investigation. A whistleblower reporting anonymously should provide as much information as possible not to compromise the ability to investigate the report fully. At this stage, the Senior Leadership Team may reach out to you for additional information through available channels.
- Investigation. The Senior Leadership Team will appoint an investigator with no personal interest in the matter to conduct an investigation. The Whistleblower Committee may also bring inoutside advisors such as lawyers, accountants, and auditors to conduct the investigation.
- Action. Minor Hotels Australasia will take action as required, including disciplinary action, implementing new policies and/or where appropriate, will notify relevant external parties such as ASIC, APRA, the ATO or the Federal Police. You will be informed of the outcome of the investigation, subject to data privacy and confidentiality obligations.
- 10. How will I know what happens to my report?
As part of our investigative process, we will send updates to you. These updates can include confirmation of the receipt of a report, request for additional information, confirmation that the Company has begun the investigation, and the outcome of the investigation and action that were taken. Our commitment is that you will be updated while the investigation is ongoing. We will strive to provide as much feedback on the investigation as possible.
- 11. Who do I contact if my complaint is outside of Australia and New Zealand?