WHISTLE BLOWER POLICY

This policy applies to all Les Mills teammates globally.

We (Les Mills) are committed to adhering to the highest standards of ethical, moral, and legal conduct for our operations. To maintain these standards, we encourage all our teammates (inclusive of instructors, suppliers, and contractors) who have concerns about suspected misconduct or illegal, unethical, or corrupt conduct by an individual or group representing Les Mills, to come forward to express these concerns without fear of reprisals.

This policy outlines how you can raise concerns (informally or formally, with options for internal, external, and anonymous reporting) regarding actual or suspected illegal activities or conduct which you identify in our workplace, at a filming, training, function, or any Les Mills event with the confidence that your concerns will be addressed (this is sometimes called “whistle-blowing”). It explains your options to consider before making a report, and the processes you should follow should you choose to do that, as well as the protections available to you. If local laws require a higher standard than set out in this policy, we will comply with the requirements of the relevant law.

We are working to build a championship-winning team around the world – understanding this policy is an important part of making that happen.

THE DETAIL

What type of conduct can be disclosed?

This policy is intended to cover disclosures where you believe you are acting in the public interest. Personal grievances will not be covered by this policy.

Matters that can be reported under this policy include (but aren’t limited to):

conduct or practices which are dishonest, corrupt, or illegal
unlawful, corrupt, or irregular use of money or resources
criminal offences
inappropriate accounting, internal accounting controls, compliance, or auditing matters
theft, fraud, or misappropriation of assets
significant mismanagement or waste of funds or resources, including environmental damage
health and safety
discriminatory conduct
child welfare
harassment, bullying, violence, abuse, or mistreatment of any kind
information security or privacy

We take all such reports seriously. Equally, we expect that reports are made in good faith, are truthful and can be substantiated. Where an investigation concludes the report was not made in good faith, malicious or false, we may launch an investigation into the person who made the report and take the appropriate action.

OPTIONS TO CONSIDER BEFORE REPORTING A CONCERN

If the behaviour of an individual or group is directed towards you, there are a few steps to consider when making a decision about whether to report a concern. Whichever route you choose, be sure to keep written records of the incident/s, noting the date and time of the incident/s and the parties involved (including witnesses, if any).

Speak to the individual/group directly

If you feel comfortable approaching the person or group directly, consider speaking with them as a first step. Explain that their behaviour is offensive, unwelcome, or otherwise, and that you would like it to stop. This can be a great option as it may be that the person does not understand the impact their behaviour is having on you.

Facilitated discussion

If speaking to the individual or group directly has not worked or you are not comfortable doing this yourself, consider requesting a support person to help you speak to them or to speak to them informally on your behalf (with or without you being present), so you are heard in a safe environment.

Make a report

If speaking with the individual or group directly, including facilitated discussions, hasn’t stopped the behaviour, or you believe the behaviour requires more serious action, or you aren’t comfortable with either approach, you may choose to make a report.

REPORTING A CONCERN

We aim to create an environment in which all our teammates, instructors, suppliers, and contractors feel free to raise concerns about conduct which may be contrary to Les Mills’ Code of Conduct, or illegal, inappropriate, unethical, corrupt, or against Les Mills’ policies.

How do I make a report?

You can report a concern either internally or using Les Mills’ independent external reporting service. If you choose the external option you will also be able to make the report anonymously, however, please note that this may limit our ability to fully investigate your allegation. Whichever option you choose, you can be confident that if you raise a concern truthfully and in good faith you can do so without fear of reprisal, dismissal, or discriminatory treatment.

Internally

You can report a concern directly with your team leader; local Head of People and Culture; local Head of Instructor Experience or Training; or any member of your local Senior Leadership team, in person (if you feel safe doing so), by letter, email, or telephone.

If you are not comfortable raising a concern with one of these people, or it is not appropriate in the circumstances, you can make your disclosure via complaints@lesmills.com which will be received by Les Mills’ CEO of Global Markets.

Externally

If you do not feel comfortable reporting a concern with any of these people or you have done so and feel that the matter remains unresolved, you can make a report through our external reporting system (IntegrityCounts) administered by an independent company. This is accessible from any country in which Les Mills operates, 24 hours a day, seven days a week, 365 days a year. This service is available for you to raise concerns (anonymously if you choose) regarding actual or suspected misconduct.

You can make a report:

Online: https://integritycounts.ca/org/lesmills
Phone: https://integritycounts.ca/call-the-hotline
Email: lesmills@integritycounts.ca

There may be circumstances where it would also be appropriate to report your concern to a relevant external authority, such as the Police. Your local Head of People and Culture can support you in making such a report if you wish.

What information do I need to provide?

A report should include enough information to allow us to investigate it properly. This may include (but is not limited to) dates and times of the alleged illegal or unethical conduct, notes from discussions or meetings; accounting or financial records or documentation; witness statements.

What happens after I’ve made my report?

If you have raised a report, you will receive acknowledgement within three [3] business days. It will be assessed by Les Mills’ Whistle Blower Protection Officer or the CEO of Global Markets and assigned to the appropriate person/s (Reviewer) who will decide on the best course of action to deal with it. That may mean:

Managing the complaint internally and communicating with you on the IntegrityCounts platform (if you have raised a concern through IntegrityCounts, you will receive a unique user login and password, which you can use to identify yourself to the independent contact centre agent or to login to the web portal to check the status of your report or to add more information) or by email, depending on how you made your complaint; or
Outsourcing the investigation to an external provider.

The Reviewer will then discuss and decide the appropriate action to take in order to ensure (1) immediate steps are taken as necessary to protect Les Mills, the public and any individuals likely to be affected; and (2) the disclosure is escalated as appropriate to ensure that it is addressed promptly and appropriately. Depending on the nature of the allegation, this may include involving the Police or other appropriate external authority. Every teammate and director will be required to cooperate in internal investigations of illegal or unethical behaviour.

How am I protected if I make a report?

Your report will be protected:

in accordance with any applicable local whistle blower law in your country;
if the information is about serious wrong doing in or by your workplace;
if you reasonably believe the information is true or likely to be true; and
if you want the serious wrongdoing to be investigated.

Your report won’t be protected if:

you know the allegations are false; or
you act in bad faith

If your report is protected, we will take the following steps to protect you from possible repercussions:

We will keep your identity and disclosure confidential to the fullest extent required by law
We will protect you from retaliatory action or personal disadvantage for making the disclosure, as long as you have acted in good faith and not engaged in illegal or unethical activities
Depending on the nature of the allegation, you may also be protected from civil and criminal, or disciplinary proceeding for having made the allegation

ANY QUESTIONS?

Please contact your local Head of People and Culture, Instructor Experience or Training.

AMENDMENTS

Les Mills may change this policy at any time as required.