1. FAQs

A: We believe that our employees are our most important asset. By creating open channels of communication, we can promote a positive work environment and maximize productivity.

EthicsPoint, as an independent global organisation, helps us to do that by providing secure, confidential telephone and web-based systems for use by Toll employees, contractors and other third parties wishing to report fraud or other improper or unlawful conduct in the workplace, including breaches of our Code of Practice.

A: To help make Toll an honest, safe and fair place to work and to help Toll identify wrongdoing that may otherwise remain uncovered. Fraud and improper conduct can have a negative effect on our workplace and reputation. By reporting fraud and improper conduct you can help us uphold our reputation and take steps to ensure everyone is secure and safe in our work environment.

A: When you observe some behavior that you believe may breach our Code of Practice or involve a fraud or some other improper or unlawful conduct, we expect you to report it. To facilitate Toll being able to address and investigate such matters in a consistent, timely and appropriate manner, our preference is for you to report such matters to the Toll Disclosure Hotline or to the Chief Compliance & Security Officer.

Ideally, you should raise personal employment-related grievances and other day-to-day concerns at any time with your line manager, supervisor or Group HR representative. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. In those circumstances, we encourage you to use the Toll Disclosure Hotline. We would rather you report anonymously than keep the information to yourself.

A: With the Toll Disclosure Hotline, you have the ability to file a confidential report via either the telephone or the internet. You also have the option of remaining anonymous. All reports are treated confidentially.

A: The more details Toll has, the better we are equipped to address concerns. We understand that you may not always have all the details of the information that has led to your suspicion. However, the types of information you may provide when reporting a suspected incident of improper conduct includes:

• nature of the conduct, including, if applicable, financial value of losses or laws or policies believed to have been breached;
• date, time, location of incident(s), and the known duration of the conduct/incident(s);
• names of people or organisations (e.g., third parties) suspected to be involved;
• business units, divisions and policies suspected of being affected by the reported conduct;
• details of any supporting evidence that may assist an investigation;
• names of any potential witnesses;
• details of any money or assets involved;
• how often the incident has happened;
• the grounds for your suspicion and how you became aware of the information;
• any other details of any evidence available that may assist an investigation.

A: Telephone calls to the Toll Disclosure Hotline are not recorded, nor is there caller ID to identify the call. Your report will be known only by a reference number unless you choose to identify yourself to the call centre operator.

Reports are entered directly on the Disclosure Hotline secure server to prevent any possible breach in security. The system makes these reports available only to specific individuals within Toll who are charged with evaluating the report. Each of these report recipients undergo training in order to maintain confidentiality.

Any suspected fraud, theft, dishonesty, criminal or unethical behaviour, bribery or corruption or conflicts of interest within Toll, other breaches of the Toll Group Code of Practice or Supplier Code of Practice, and any other types of Reportable Conduct or Disclosable Conduct (as described in Toll’s Whistleblower Policy).

Ideally, you should raise personal employment-related grievances and other day-to-day concerns at any time with your line manager, supervisor or Group HR representative. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner or have concerns about potential retaliation or other detrimental action. In those circumstances, we encourage you to use the Toll Disclosure Hotline.

A: Report it anyway. Most cases reported are uncovered through tips from honest people. The operators who take the calls do not expect you to know every last detail. Report what you know.

Toll is responsible for confidentially assessing and/or investigating all reports. After you have made an initial report, Toll may contact you (as summarised below) to clarify issues or request further details or information.

When you file a report at the Disclosure Hotline Web site or through the Call Centre, you receive a unique user name and are asked to choose a password. You can return to the Hotline system again either by Internet or telephone and access the original report to add more detail or answer questions posed by a company representative and add further information that will help resolve open issues. We strongly encourage you to return to the Toll Disclosure Hotline in the time specified to answer company questions. If you wish to remain anonymous or provide a pseudonym or alias, both you and Toll may have an “anonymous dialogue".

If you agree to identify yourself and be contactable, Toll may confidentially contact you to clarify details which may assist in their investigation.

A: Within one business day EthicsPoint will provide a report to a designated Toll representative who will determine the appropriate action required.

A: Toll will not tolerate its employees or officers taking or threatening to take detrimental action against persons who make complaints on reasonable grounds, regardless of whether or not the underlying facts prove to be correct or result in any corrective action. If you believe you have faced detrimental action of any kind, call the Disclosure Hotline and report the matter.

A: Detrimental Action means any action taken or threatened against a person in reprisal for reporting improper conduct including:

• dismissal
• demotion or alteration of position or duties disadvantageously
• any form of intimidation or harassment
• discrimination
• damage to a person’s property, reputation, business or financial position or any other damage to a person
• any action which may discriminate, disadvantage or adversely affect a person’s employment

Actions such as reasonable administrative action for the purpose of protecting a person from detrimental action or managing a reporter’s unsatisfactory work performance in line with Toll’s performance management framework are not detrimental actions.

A: No. Rewards are not offered.

We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the livelihood of an entire company.

A: No. You can contact the Toll Disclosure Hotline as many times as you wish to report suspected improper conduct.

A: The information reported to the Toll Disclosure Hotline is forwarded to a dedicated Toll representative appointed to address incidents of improper conduct. If he or she decides that corrective action is necessary, then they may notify the appropriate law enforcement agency if such action is warranted.

A: We will look to assess what action should be taken on a case-by-case basis (including but not limited to deciding if it is a Qualifying Disclosure and if yes, how to best protect your identity and to protect you from Detrimental Action). Whether there is an investigation depends on a number of factors including the information provided, the details, documentation and company policy. If you have any personal issues or concerns (including fear of detrimental action being taken against you) in the matter, we encourage you to tell the Disclosure Hotline operator when you first call the Hotline. If we feel that the matter may fall more properly within existing Toll business or grievance procedures, we will ask you whether you have spoken with your supervisor, manager or HR.

A: The Toll Disclosure Hotline will collect information that you voluntarily provide. You are not required to provide information about you in order to participate in the service.

A: The Toll Disclosure Hotline will only collect information about others which is necessary to provide the Toll Disclosure Hotline service.