Speak Up Policy (Policy) Appen Group (Global) - Version 1.0 Issue date 10.01.2020 - Appen 9
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Speak Up Policy (Global)
Speak Up Policy (Policy)
Appen Group (Global)
Version 1.0
Issue date 10.01.2020
Page 1 of 5Speak Up Policy (Global)
1. PURPOSE AND SCOPE
Appen wants to make sure it is always conducting its businesses legally. We want people who are
concerned about improper conduct to feel comfortable reporting that conduct. The purpose of this
policy is to explain how you can do that, and what we will do when we receive reports.
The Policy applies globally. It applies to all Appen’s subsidiaries, businesses, divisions, and offices
(Group). It also applies across all jurisdictions where we operate. If local legislation, regulation, or
laws provide a higher level of protection than what is included in this Policy, the local legislation
controls.
The Policy does not form part of any contract of employment or any industrial instrument.
2. WHO IS A REPORTER?
You are a Reporter if you make or attempt to make a disclosure of improper conduct.
A Reporter can be:
• directors, officers, managers, employees (including part-time, casuals, secondees, interns etc);
• contractors, consultants, suppliers, service providers (or their employees or subcontractors);
• auditors;
• former employees of the Group;
• family members of any of the above.
Reporters are sometimes referred to as “whistleblowers”.
Improper conduct includes any conduct or an improper state of affairs that is:
• dishonest;
• fraudulent;
• corrupt;
• illegal;
• violates the law, a regulation or any legal code;
• in serious breach of internal policy (including our Code of Conduct);
• inconsistent with our corporate values;
• inconsistent with the Appen ESG statement;
• unethical;
• improper;
• unlawfully discriminatory;
• bullying and harassment;
• creates an unsafe work environment; or
• detrimental to the interests of Appen or that may cause us financial or non-financial loss
(including reputational harm).
3. MAKING THE DISCLOSURE
As a Reporter, you can make a disclosure in any of the following ways:
• Whistleblowing/Anonymous Reporting via web and mobile below;
• Anonymous web reporting via IntegraCall at https://appen.integracall.com/webportal.
• Via the IntegraCall app which can be downloaded from the Apple store or Google Play for use
Page 2 of 5Speak Up Policy (Global)
iPhone or Android phones (the company code is APPEN (all UPPER CASE)).
• Speak with an officer, director, the company secretary or a member of the executive team at
Appen; or
• Speak with Appen’s external auditor (currently KPMG).
You must act honestly and reasonably in making the disclosure, with a genuine belief that the
improper conduct has occurred.
4. CONTENT OF THE DISCLOSURE
You should include as many of the following details as you have in your disclosure:
• the nature of the conduct that concerns you;
• the details of the person you think engaged or is engaging in any relevant conduct;
• when and where the conduct occurred (e.g. dates and times);
• details of anyone else aware of or involved in the conduct;
• details of anyone else who might be able to verify your disclosure;
• if you have done anything in response to the conduct;
• if you have any concerns about possibly being victimised, and if so by whom; and
• any supporting information (e.g. documents, file notes, emails, photographs).
5. ANONYMITY AND CONFIDENTIALITY
If you want to make an anonymous disclosure or restrict your disclosure to only certain people, we
will respect that request.
Specifically:
• You have the right to remain anonymous and do not need to identify yourself at any time during
the investigation process.
• Appen may use tools and platforms that help protect your identity.
• At no time will Appen force you to reveal your identity.
• You can refuse to answer questions you feel could reveal your identity.
• If you choose to reveal your identity at any time, we will document who will have access to that
information.
At any time, you can choose to identify yourself, but this is your choice and at no point do you need
to do this nor will you be forced to provide your identity.
There are some limited situations where Appen may not be able to comply fully with your request as
a Reporter to remain anonymous. For example, where:
• we are compelled by law to do so (for example, where Appen receives a valid subpoena);
• there is an immediate and substantial risk to the health or wellbeing to you or another person
(for example, where a disclosure suggests you might engage in self-harm or harm others);
• we need to engage external legal counsel in order to obtain legal advice;
• we use a specialist external investigator;
• we consider we are obligated to make a disclosure to a regulator or the police under legislation
(for example, where a felony has been reported we may be required to report it to the police);
or
• there is an imminent risk of serious harm or danger to public health or safety, or to the financial
system, if the information is not acted on immediately.
Page 3 of 5Speak Up Policy (Global)
Whilst we will still make best endeavours to investigate the disclosure, there may be some practical
limitations in doing so if you do not agree to share your disclosure or identity.
6. THE INVESTIGATIVE PROCESS
1. Once your disclosure is submitted (anonymous or not), this report goes to the General Counsel
(or if the disclosure concerns the General Counsel then to an unimplicated non-executive
director of the Board).
2. We will send you an acknowledgment of the report and introduce you to the investigator, who
may have additional questions for you. We may investigate the disclosure internally or use
third-parties to investigate any disclosure.
3. As appropriate you will be advised of the process of the investigation. You should understand
that investigations may be delayed when witnesses are traveling or on leave, so while we will
try to get investigations done quickly, this is sometimes beyond our control.
4. Once the investigation is done, you will be provided with a high-level summary of the outcome
of the investigation. There may be information that cannot be shared with you.
5. If, after receiving the high-level summary of the investigation, you are not satisfied with the
result, you may request an escalation in writing along with details as to the basis for the request.
The appropriate escalation path will be determined on a case-by-case basis.
7. RETALIATION PROHIBITED
We prohibit all forms of retaliation against you as a direct result of being a Reporter or a witness in
an investigation. Retaliation is negative action against you because of your participation as a
Reporter, such as:
• termination of employment (unless unrelated and in the ordinary course of business),
• disciplinary action;
• performance management (unless unrelated and in the ordinary course of business);
• harassment or bullying;
• personal or financial disadvantage; or
• unlawful discrimination.
If you feel that you have been or will be retaliated against, you should escalate this immediately to
the General Counsel or SVP of HR. The General Counsel or SVP of HR will investigate the retaliation
and take the action they feel is appropriate in order to address any valid concern. If you feel your
report of retaliation was not resolved adequately you can escalate this case in writing to the CEO or
the Board.
We have discretion to grant a Reporter who has not engaged in serious or unlawful conduct,
immunity from company disciplinary action relating to matters that come to light as a result of their
disclosure. We may raise with you matters that arise in the ordinary course of your employment or
engagement (e.g. individual performance or misconduct issues) and which are separate from the
matter disclosed.
8. SUPPORT
If you are a current or former employee, you can access our EAP for emotional support. While we
may not be able to provide the same level of practical support to non-employee Reporters, we will
look at ways to provide you support to the extent reasonably possible.
Page 4 of 5Speak Up Policy (Global)
9. REPORTING TO REGULATORS
Nothing in the Policy is intended to restrict you from disclosing improper conduct, providing
information to, or communicating with a government agency, law enforcement body or a regulator
in accordance with any relevant law or regulation in any jurisdiction in which we conduct business.
10. BREACH OF POLICY
Breach of this Policy may be regarded as misconduct, which may lead to disciplinary action
(including termination of employment or engagement). Any breach of confidentiality of the
information provided by a Reporter, or of a Reporter’s identity, and any retaliation against a
Reporter, will be taken seriously and if appropriate will be separately investigated. Any individual
who is found to have disclosed the information or to have retaliated (or threatened to retaliate)
against a Reporter may be subject to further action (including disciplinary action in the case of
employees). An individual may also be exposed to criminal or civil liability for a breach of relevant
legislation.
11. UPDATING THE WHISTLEBLOWING POLICY
From time to time, and at least annually, we may update this Policy. Any changes to this Policy
will be communicated with all employees and any relevant stakeholders and must be approved by
the CEO. Any changes will be reported to the Board as below.
12. REPORTING TO THE BOARD OF DIRECTORS
The Board is updated at each Board meeting on the Policy, and any reports, investigations, and
results taken under it. Reports or investigations carrying an undue amount of risk will be reported
to the Board outside of the monthly updates. The Board at any time can ask about matters arising
or pending under the Policy. The Board is responsible and accountable for oversight of the
implementation and effectiveness of the Policy.
Other Related Documents
Code of Conduct
Securities Dealing Policy
VERSION CONTROL
Version Purpose/change Author Date
1.0 Initial release Carl Middlehurst 10.01.2020
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