The protections and processes set out in this policy apply to Whistleblowers in relation to any Eligible Disclosure.

Whistleblowers are present and former people engaged to work for any company within the Zimmermann group (collectively or individually, Zimmermann), those who supply goods or services to Zimmermann and any associate of Zimmermann. These processes and protections also extend to relatives, dependents or spouses of individuals entitled under this policy. 

An Eligible Disclosure is a disclosure made by a Whistleblower to an Eligible Recipient about Reportable Conduct (see definitions below). 

As Zimmermann has operations and staff in multiple countries, this policy is subject to the whistleblower laws that apply in each particular country. As a result, the scope of this policy and the manner in which disclosures made under this policy are handled, may differ according to the laws and requirements in the jurisdiction in question. Where there is a variance between this policy and the legal requirements of a particular jurisdiction, the more rigorous standard will apply.

You may report under this policy if you have reasonable grounds to suspect that a Zimmermann director, officer, employee, contractor, supplier, tenderer or other person who has business dealings with Zimmermann has engaged in Reportable Conduct.

Reportable Conduct includes misconduct or an improper state of affairs (actual or reasonably suspected). This can involve:

• fraud, bribery or corruption;
• illegal acts, failure to comply with any legal or regulatory obligation that harms the public interest or the financial integrity of Zimmermann or another entity, or failure to comply with any other legal or regulatory obligations expressly covered by local Whistleblower laws;
• a danger to the public or environment.

Reportable Conduct does not include personal work-related grievances. Personal work-related grievances relate to an individual’s own employment or previous employment and have implications for the individual personally without having significant implications for others, Zimmermann or the public interest.

Examples of personal work-related grievances include complaints in relation to terms of employment, interpersonal conflict with another employee, disciplinary or performance management process, or termination of employment. Any complaints of discrimination, bullying or harassment should be dealt with in accordance with the procedure set out in Zimmermann’s discrimination, bullying or harassment policy.

Reports of detrimental conduct taking place as a consequence of an Eligible Disclosure will be covered by this policy.

Whistleblower protections are available if Reportable Conduct is reported in compliance with this policy or otherwise reported directly to an Eligible Recipient as defined under local legislation around the world. In Australia the Eligible Recipients are any officer or senior manager of Zimmermann and any internal or external auditor or actuary of Zimmermann. 

To best ensure that processes are followed and protections afforded, Zimmermann requests that Whistleblower complaints are made by contacting Zimmermann’s Confidential Whistleblower Hotline on the below numbers

Zimmermann’s Confidential Whistleblower Hotline:

AU:        + 61 283116940

UK:        + 44 2030531599

France: + 33 188454741

Italy:      + 39 0810067928

USA:      + 1 7866236450

The Whistleblower Hotline allows disclosure to be made anonymously. As such any Whistleblower may choose to raise their Whistleblower complaint anonymously and to maintain anonymity during any investigation that may take place. However, where appropriate and possible Zimmermann encourages Whistleblowers to consider identifying themselves and providing their contact details, so that we can look into the matter more easily, effectively, and efficiently. In addition, it enables Zimmermann to protect you against any retaliation or reprisals, request further information to assist any subsequent investigation, and provide you with feedback as appropriate and permitted by applicable laws.

We hope any potential Whistleblower will feel comfortable to voice whistleblowing concerns openly under this policy. However, Whistleblowers are entitled to anonymity under legislation and in certain cases, anonymity can be crucial in reaching the goals of this policy. If a Whistleblower wishes to maintain anonymity, Zimmermann will make every effort not to reveal the identity of a Whistleblower without their permission, unless there are legal requirements to do so.

In any investigation that takes place following an Eligible Disclosure, where anonymity has been requested, so far as reasonably possible Zimmermann will neutralize any reference to the Whistleblower, such as avoiding the use of gendered pronouns or reference to the specific team of a current or previous employee. Whistleblowers who wish to remain anonymous should also take precautions not to disclose their identity, such as avoiding discussion of the complaint made, other than to the Eligible Recipient or anyone investigating the matter.

All documents and other materials relating to Eligible Disclosures will be stored securely and only accessed by those directly and necessarily involved in managing or investigating the disclosure. Each person involved in any investigation or other management of an Eligible Disclosure will be bound by Zimmermann’s confidentiality requirements. All processing and storage of data as part of Zimmermann’s whistleblowing framework or resulting from this policy will be made in accordance with applicable laws and regulations on data protection.

We encourage Whistleblowers to raise any specific concerns about possible reprisals that may follow if a Whistleblower’s identity is known or revealed at the outset, at time of raising the Eligible Disclosure. This will assist Zimmermann to put in place appropriate measures.

While reports can be made anonymously, it is important to note that this may affect our ability to investigate the matter properly and to communicate with you about your report.

All reports will be taken seriously. On receiving a disclosure from a Whistleblower, Zimmermann will undertake an initial assessment to confirm whether the disclosure qualifies for protection and determine an appropriate course of action, which may include further investigation.

Where Zimmermann does not have any means to contact the Whistleblower, it may be unable to conduct any investigation.

If appropriate, an investigation will commence as soon as reasonably practicable. All investigations will be conducted impartially and in accordance with all applicable laws and policies.

Zimmermann aims to have initial assessment complete and any required investigations commenced within 21 days of receipt of the Eligible Disclosure. If Zimmermann believes it is appropriate, it may choose to engage a third-party provider to conduct the investigation, otherwise an appropriately impartial internal person will be appointed to manage the investigation.

Unless it is not possible to do so, Zimmermann will advise the Whistleblower if an investigation is to take place or not. Zimmermann will also provide the Whistleblower with updates unless it is not possible to do so. The nature and timing of these updates will vary depending on the nature of the Eligible Disclosure.

All steps taken in an investigation will be kept as confidential as possible in the circumstances. All involved persons will be advised of the confidential nature of the investigation.

If appropriate, Zimmermann will share the outcome of any investigation with the Whistleblower. This may not always be appropriate and in some instances it may only be appropriate for Zimmermann to share limited details of its conclusion.

No Whistleblower will be disadvantaged for making an Eligible Disclosure. Any such disadvantage directly opposes Zimmermann’s values and is expressly prohibited under legislation when certain requirements are met. 

When an Eligible Disclosure is made, the Whistleblower will be protected from any act of reprisal or retaliation. No detrimental conduct or threat of detrimental conduct will take place as a result of an Eligible Disclosure. If you believe that you have suffered any such conduct, you should inform Zimmermann’s Global Head of HR immediately. Any current team member who engages in retaliatory conduct in breach of this policy will be subject to disciplinary action.  Whistleblowers can seek to take legal action if unlawful detrimental conduct occurs as a result of their Eligible Disclosure.

For the avoidance of doubt, the following does not amount to detrimental conduct:

• Reasonable administrative action taken for the purpose of protecting the Whistleblower (for example moving the Whistleblower if their complaint relates to their immediate work area); and
• Managing a Whistleblower’s performance or conduct in line with Zimmermann policies and procedures.

Any person who seeks legal advice in relation to a disclosure under this policy or relevant legislation is also protected from any detrimental action taken as a result of their disclosure to the legal practitioner.

Zimmermann will have regard to the relevant legislation of the country of operation in respect of the protection of Whistleblowers.

Whistleblowers remain entitled to the protections set out in this policy even if ultimately the Reported Conduct is not proven however, such protections are only available where the discloser has reasonable grounds to suspect the Reported Conduct.

The motives of a Whistleblower are not relevant to the processes and protections available, however Whistleblower protections are not available where the disclosure is:

• Trivial or vexatious in nature with no substance; or
• Unsubstantiated allegations which are found to have been made without reasonable grounds, or knowingly false.

Disclosures made in the above circumstances will be viewed seriously and may be subject to disciplinary action that could include dismissal, termination of service or cessation of a service or client relationship.

The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing and we encourage Whistleblowers to raise concerns internally in the first instance, so that concerns can be addressed quickly and remedied directly.

The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator or designated authority in your country (or, in the European Union, an EU-level regulator or authority). In Australia this includes ASIC, APRA, or another body prescribed by regulation. In cases of public interest or emergency disclosures previously raised with ASIC, APRA or another body prescribed by regulation, disclosures can be made to parliament or a journalist if certain specific criteria set by legislation are met.

Nothing in this policy prohibits (or should be understood as prohibiting) the reporting of known violations of law to any government agency, regulatory body, whistleblowing authority. Noting that whistleblower protections will only be available for disclosure made in accordance with local laws and this policy.

Some countries have specific laws associated with whistleblowing, which means that in some countries there may be country-specific procedures. Whistleblowers who would like more information on applicable local legal requirements, reporting channels, and resources should contact Zimmermann’s Global Head of HR or Zimmermann’s Confidential Whistleblower Hotline.