Key Information – Reporting procedures:
6.1 How to report
- (a) Any person (referred to below as ‘whistleblower’) who believes reasonably and in good faith that Reportable Conduct has occurred, is occurring or is likely to occur, should raise their concern immediately:
- (i) with the relevant Local Compliance Officer within the organisation of the Developer, IAI Fund Manager or the Co-Developer in the first instance;
- (ii) with the InfraCo Compliance Function if the report concerns the Reportable Conduct of the Local Compliance Officer; or
- (iii) through the external, confidential and independent “InfraCo Compliance Hotline”, operated by Safecall (see section 6.4 below).
- (b) The InfraCo Compliance Function may be contacted as follows:
- (c) If the whistleblower suspects that either the InfraCo Compliance Function or the Local Compliance Function are involved in the conduct, then they may report suspicions directly to the Chairman of the Audit & Risk Management Committee of IAD (the ARC):
- (d) InfraCo have also arranged to outsource an external, confidential and independent “compliancehotline” with Safecall Limited, located in the United Kingdom (see section 6.4 below);
6.4 InfraCo compliance hotline
- (a) InfraCo Compliance Hotline (Safecall): InfraCo has arranged to outsource an external, confidential and independent “compliance hotline” with Safecall Limited, located in the United Kingdom.
- (b) Safecall provides a 24 hour a day, 7 days a week service. When contacting Safecall, whistleblowers will be put in touch with trained operators who can make required arrangements regarding language and mode of reporting so as to allow the whistleblower the most convenient and comfortable channel through which to make a report.
- (c) The InfraCo Compliance Hotline can be contacted through telephone as follows:
* InfraCo has used its best efforts to arrange through Safecall for ‘freecall’ services to be made available for most of the countries that InfraCo is mandated to cover. However, this was not possible for all countries.
- (d) InfraCo encourages whistleblowers to make reports openly and to disclose their identity to those they are reporting to under this Policy. However, InfraCo recognises that individuals may prefer in certain circumstances to make a report anonymously.
- (e) All calls received through the InfraCo Compliance Hotline will be treated confidentially and guarantee anonymity, should the whistleblower prefer.
- (f) The above being said, where a whistleblower chooses to report Reportable Conduct anonymously, the value of the information may be limited and may hinder the ability of InfraCo to fully investigate the matter. Further, it may in certain circumstances prevent the whistleblower from accessing additional protection at law.
6.5 Reporting in good faith
- (a) InfraCo shall endeavour to ensure that no one who reports any concern under this Policy in good faith will be subjected to any prejudice by InfraCo or any person within its control for coming forward, regardless of whether or not the concern is ultimately substantiated.
- (b) In the event that a whistleblower believes that they are being victimised or subjected to prejudice by InfraCo or any person within its control as a result of reporting Reportable Conduct or assisting the company in any investigation under this Policy, the whistleblower should inform the Local Compliance Officer or the InfraCo Compliance Function immediately so that appropriate action can be taken to protect them from any reprisal by InfraCo or any person within the control of InfraCo (see also section 8 on protection of whistleblowers).
- (c) If during the course of the investigation it is discovered that the matter has been reported maliciously, then the whistleblower will be subject to investigation and potential disciplinary action may be taken by InfraCo.
- (d) In the event that the whistleblower is an external party, InfraCo reserves the right to commence legal proceedings against the external party for making false statements that may harm the reputation of InfraCo.
6.6 Confidentiality of reporting
- (a) InfraCo shall endeavour to keep all reports of Reportable Conduct confidential to the extent possible, subject to legal and regulatory requirements applicable to InfraCo.
- (b) Please bear in mind that local laws may require InfraCo to report complaints and allegations of Reportable Conduct to various government regulators under certain circumstances.