Upon receipt of a whistleblowing (WB) complaint, the independent WB Unit will channel the WB case for investigation to an independent party to ensure that there is no conflict of interest.
At the completion of the investigation, the investigation team will report to the WB Unit on the results of the investigation, including a conclusion on the validity of the allegations (proven/ not proven) and the proposed recommendation(s) to address the wrongdoing and/or process limitations. In ensuring that all WB cases reported are appropriately investigated and addressed, a management level WB Committee reviews the outcome of all investigations prior to tabling of all cases to the independent Governance and Audit Committee for their final deliberation before case closure.
Throughout the above process, the identity of the whistleblower is kept confidential at all times and will not be disclosed to any of the above parties. The separation of roles among the WB administrator, investigation team, and oversight body provides the required check and balance on the independence of the WB reporting mechanism.
If the whistleblower is not satisfied with the way in which his/her concern has been handled, he/she can raise it with the GAC Chairman. All appeals to the GAC Chairman must be in writing (gacchairman@sdguthrie.com) and supported by valid and cogent justification. Decision of the GAC Chairman shall be final and binding.