Policy on Reporting Unethical Activity

Leading Language is committed to transparency, integrity and accountability, ensuring that our business is conducted according to the highest ethical standards. Our value system is aligned to the Sustainable Development Goals and the principles promoted by the UN Global Compact.

We commit to the ethical and lawful undertaking of all our business activities, and have various policies, procedures and practices in place to ensure that we do not deviate from the path of integrity. In the event that such deviations occur, we aim to recognise these as quickly as possible and to take prompt and appropriate remedial action.

The purpose of this policy is to set out the expectations, obligations and rights of all our stakeholders regarding the reporting of suspected or known unethical activity involving or affecting Leading Language.

The importance of reports of suspected or known unethical conduct

Unethical and unlawful activity can have a severely detrimental effect on the financial sustainability and good reputation of any business. While Leading Language maintains appropriate internal control systems, it also relies upon its stakeholders to bring to its attention any incidents of suspected or known unethical conduct in order that these can be promptly identified and effectively curtailed.

The obligation to report suspected or known unethical conduct

Those who serve Leading Language in a governing, employment or contracting capacity have a legal obligation to act in its best interests, and this includes drawing its attention to suspicions or knowledge of wrongdoing involving or affecting it. Failing to bring such concerns or knowledge to the attention of Leading Language will be considered a breach of the trust relationship that must exist between the employer and the employee / contractor. It is similarly expected that those who are suppliers and potential suppliers of goods and services to Leading Language, and who seek an ongoing relationship with the company, will draw its attention to suspected or known wrongdoing. Our clients play an equally vital role in supporting the Leading Language integrity commitment, for it is in their interface with us that they may become aware of any deviations from ethical and lawful business practices that need to be addressed.

Criteria for submitting a report in terms of this Policy

Any report of suspected or known unethical activity should contain only allegations or information that are true to the best knowledge of the party making a report. The following are examples of matters that should be reported in terms of this Policy and are subject to the rights and responsibilities contained in the Protected Disclosures Act of the Republic of South Africa (2000), as amended: Failure to comply with a legal obligation | An actual or likely miscarriage of justice | The endangerment of the health and safety of a person or the environment | Unfair discrimination in terms of Chapter II of the Employment Equity Act or the Promotion of Equality and Prevention of Unfair Discrimination Act.

Beyond the above matters outlined above, as set out in the Protected Disclosures Act, Leading Language seeks reports of any unethical or unlawful activity, and any deliberate breach of its policies, procedures and values.

Reports should be made as soon as possible once any suspicions arise or any knowledge of wrongdoing is obtained.

Matters that are appropriately addressed in terms of internal query or grievance procedures should continue to be raised in terms of normal management procedures.

Guidelines for the contents of a report

The contents of a report play a key role in enabling Leading Language to investigate and address the matter raised.

Those reporting unethical activity can use the following content structure when making a report, to the extent that it is applicable to the matter concerned:

Describe the matter you wish to report in as much detail as possible.
If applicable, detail the date and time when the event occurred, or explain when it usually occurs if it is an ongoing matter.
Provide information regarding the people and parties involved in the matter, identifying whether they are engaged by Leading Language or another entity.
Advise if there are others who may know about and have information about the wrongdoing.
Explain how you believe Leading Language should investigate the matter or where and how evidence of the wrongdoing will be found.
Convey any concerns you have about a) how the matter is investigated and b) who is involved in the consideration and investigation of the report.
Provide any supporting evidence that you may have.
If you are willing to be available for follow-up discussions, provide your name and contact details, and state if you wish your identity to remain confidential.

How to report suspected or known unethical conduct

We encourage open reporting by all stakeholders, as this two-way communication approach is most effective in promoting understanding of matters of such importance. At the same time, we accept that some individuals will wish to share their concerns and information on an anonymous basis. In all instances, Leading Language commits to exercising the highest levels of confidentiality regarding the identity of anyone those making a report.

Procedures for open and confidential reporting

Open and confidential reports of suspected or known wrongdoing can be made in person, or via telephone or email as follows:

In respect of matters relating to sales, the Business Development & Marketing Manager:
Insert name and contact details
In respect of matters relating to training and translations, the Operations Manager:
Insert name and contact details
In respect of any matters relating to finance and procurement, and in respect of any matters that the reporter does not wish to direct to the Business Development & Marketing Manager or Operations Manager, the Managing Director:
Insert name and contact details

Where reports are made to the Business Development & Marketing Manager or to the Operations Manager, such reports will be promptly escalated by the managers concerned for the joint attention of the Managing Director.

Procedure for anonymous reporting

Anonymous reports should be made directly to the Managing Director, using a format preferred by the party making the report. For example, this may be via email from an email address that does not identify the sender, by hand-delivered mail or by post, using the following contact details:

Karen Longley

Managing Director

Insert all contact details incl. postal and physical address

How reports received will be handled

All reports received will be managed in a manner that is compliant with the provisions and protections contained in the Protected Disclosures Act. The report recipients (the Managing Director and where applicable the Business Development & Marketing Manager or Operations Manager) will maintain confidentiality regarding the identity of a reporter who has requested this. However, trusted advisory and investigative service providers who are subject to confidentiality obligations may be consulted to ensure that matters are effectively handled. Leading Language has engaged Ethicalways to provide impartial and expert support where needed in the handling of reports according to best practices.

A reporter who makes their identity known when reporting suspected or known wrongdoing may be asked to engage in consequent discussions with the internal and external investigators as applicable. However, one of the goals of such discussions will be to identify ways of taking the necessary investigative and remedial action without compromising the identity of the reporter.

While it is not possible to provide an anonymous reporter with feedback on the outcomes of any report-handling and investigation process, Leading Language commits to providing both open and confidential reporters with progress feedback according to the timelines set out in the Protected Disclosures Act.

No person who makes a report in terms of this policy, that they reasonably believe to be true, will be subjected, as a consequence of their making a report, to action that constitutes retaliation or occupational detriment.

All information received will be used to ensure that corrective action is taken to reduce the likelihood of any reoccurrence of the unethical activity concerned.

Prohibition on the misuse or hindrance of this Policy

Where this Policy is abused through the making of a report that is known to be false, or should reasonably have been known to be false, this can constitute a legal offence. If intentionally false reports are made in the context of an employment relationship, this is gross misconduct. Where intentional harm is caused and suffered through fictitious reporting, the Protected Disclosures Act provides for either or both a fine and imprisonment for up to two years.

Given the importance of this Policy to the sustainability of Leading Language, it is important that no stakeholder take any action that deters others from exercising their obligation to make a report of wrongdoing or co-operate with any arising investigations.

Contact information

For any queries or comments regarding this Policy, please contact:

The Managing Director

Insert name and contact details