Whistleblowing

AISJ Whistleblowing Policy The American International School of Johannesburg (AISJ), in alignment with its Guiding Statements, provides a mechanism for AISJ community members and commercially engaged counter parties of AISJ to raise concerns related to the School, while offering protection from victimisation, harassment or disciplinary proceedings for those who do so.

Concerns Covered by the Whistleblowing Policy An individual can raise a concern about a risk, malpractice or wrongdoing at AISJ, related to the following areas:

• Criminal Offences
• Fraud, finances and accounting;
• Bribery and corruption;
• Conflicts of interest;
• Theft, misappropriation, or misuse AISJ property;
• Breaches of privacy and information security policies;
• Endangering of health and safety of individuals;
• Causing damage and danger to the environment;
• Unfair discrimination and harassment (including bullying)
• Concern for the welfare or safeguarding of a child.
• Failure to comply with legal/regulatory obligations
• Other serious misconduct

Exclusion

The whistleblowing policy covers concerns that are related to the areas outlined above ("Concerns Covered by the Whistleblowing Procedures"). Any other employment-related concerns or complaints should be raised through the School’s grievance procedure.

Protection

AISJ acknowledges that the decision to report a concern can be a difficult one to make, not least because of fear of reprisal from those responsible for the irregularity. AISJ abides by the provisions of the Protected Disclosures Act 26 of 2000, which makes provision for employees to report unlawful or irregular conduct in the workplace. In this way, individuals are afforded protection if acting in good faith. AISJ does not tolerate harassment or victimization and will act to protect employees when concerns are raised in good faith. Maliciously making a false allegation under this policy constitutes gross misconduct and is likely to trigger disciplinary sanctions and/or legal prosecution.

Confidentiality

An individual may choose to report anonymously or disclose their identity when reporting. Should the individual disclose their identity, the School is obliged and committed to taking reasonable steps to protect the confidentiality of the individual who has reported the concern. It must be noted, however, that the investigation process may reveal the source of the information and a statement by the individual may be required as part of the evidence.

How to Report a Concern

If an individual has a genuine concern about a risk, malpractice, or wrongdoing, it can be reported by contacting an independent whistleblowing service provider.

How the Complaint Will Be Dealt With

The independent whistleblowing service provider reports all concerns received to the School’s internal Legal Advisor. Depending on the nature of the concern raised, the Legal Advisor will forward the concern to the relevant person listed below, however, if the relevant person is at all implicated, that person will not receive the information:

• Director of Operations: all concerns regarding School operations and operational employees, with the exception of concerns implicating the Director of Operations in any way
• School Director: concerns regarding the Director of Operations and all concerns regarding students and faculty, with the exception of concerns implicating the School Director
• Board of Directors: concerns regarding the School Director
• Board of Directors: reports relating to the conduct of an individual Board Director, will be referred to the Board Chair unless the Board Chair is implicated, in which case it would be referred to the rest of the Board.

The receiver of the concern will determine the appropriate next steps. In order to protect individuals accused of possible malpractice or inappropriate behavior, inquiries will be made to decide whether an investigation is necessary. Some concerns may be resolved by agreed action without the need for an investigation. If urgent action is required, this will take place before an investigation is undertaken.

If an investigation is deemed necessary, the concern raised may be:

• investigated internally by a person not implicated in the concern;
• investigated by an investigating officer appointed by the school;
• referred to the police; or
• referred to the school’s auditor

Protection of the Whistle-blower In terms of the Protected Disclosures Act a Whistle-blower who raises concerns in good faith is protected from:

• Being subjected to any disciplinary action
• Being dismissed, suspended, demoted, harassed, or intimidated
• Being refused transfer or promotion
• Change of a term or condition of employment to his/ her disadvantage
• Being refused a reference or given an adverse reference

Record Keeping

All records will be maintained by the AISJ Legal advisor

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