External Whistle-Blowing Policy

ACOSTS — ASEAN Council for Offshore Safety and Training Standards — is an industry-focused offshore safety, training, assessment and competence standards body supporting safety and competency improvement across the offshore, marine and energy sectors. ACOSTS takes whistleblowing very seriously. This policy explains what types of concerns may be raised with ACOSTS, who may raise them, how concerns should be reported, how ACOSTS will consider such concerns, and how confidentiality will be handled. This policy is intended to support the integrity of ACOSTS standards, protect learners and workers, prevent unsafe or unethical practices, and help maintain confidence in offshore safety training and certification.

This policy applies to whistle-blowing concerns raised by third parties in respect of organisations or individuals that are approved, recognised, acknowledged, monitored, audited or otherwise associated with ACOSTS. This may include concerns raised by:

• –Learners, trainees, delegates or certificate holders.
• –Current or former employees of ACOSTS-approved or applicant centres.
• –Instructors, assessors, invigilators, auditors or verifiers.
• –Contractors, consultants, suppliers or service providers.
• –Employers, offshore operators, crewing agencies or industry stakeholders.
• –Individuals who work within, or have previously worked within, organisations involved in providing ACOSTS-approved training, assessment, certification or competence services.
• –Any person who has credible information about a serious matter connected with ACOSTS standards, centre approval, training delivery, assessment integrity or certification.

If the concern relates to your employment or an internal issue within your own organisation, you are encouraged to consider using your organisation's internal whistle-blowing, ethics, grievance, compliance or safety reporting process first. However, you may contact ACOSTS under this policy if you have raised the concern internally and are not satisfied with the response, feel unable to raise the concern internally, reasonably believe the matter may be concealed or ignored, fear retaliation or victimisation, or the issue affects ACOSTS standards, approved training, assessment, certification, learner safety or the integrity of ACOSTS approval.

Whistle-blowing is the disclosure of information by an individual who reasonably believes that the information is in the public interest and relates to serious wrongdoing, safety risk, legal non-compliance, environmental harm, misconduct, fraud, concealment or other matters that may affect individuals, organisations, the public, the offshore industry or ACOSTS standards. Whistle-blowing is different from raising a personal grievance. A grievance usually relates to a personal employment matter, such as salary, promotion, workplace disagreement or an individual dispute. Whistle-blowing normally relates to wider harm or risk, such as danger to health and safety, falsification of records, unsafe training, fraudulent certification or deliberate concealment of serious issues. If you wish to raise a personal employment complaint, this should normally be raised directly with your employer or through the appropriate employment grievance process.

Concerns raised under this policy must reasonably relate to ACOSTS' role in approving, recognising, monitoring, auditing or maintaining standards for offshore safety training, assessment, certification or competence assurance. You may raise a concern if you reasonably believe that past, present or likely future actions demonstrate one or more of the following:

• –Failure to comply with a legal, regulatory, contractual or professional obligation.
• –Danger to the health or safety of an individual or group of individuals.
• –Unsafe training delivery, unsafe facilities, unsafe equipment or unsafe practical exercises.
• –Damage or risk of damage to the environment connected with training or assessment activities.
• –Deliberate concealment of any of the above.
• –Serious breach of ACOSTS standards, approval conditions or quality assurance requirements.
• –Delivery of ACOSTS-approved training by an unauthorised centre, instructor or assessor.
• –Issuing certificates without proper attendance, training, assessment or competence verification.
• –Falsification of learner attendance, training records, assessment evidence or certification data.
• –Forgery, alteration, sale, misuse or fraudulent issue of ACOSTS certificates.
• –Misuse of ACOSTS name, logo, approval status, certificate marks or official documents.
• –Bribery, corruption, improper influence or improper inducement connected with centre approval, audits, assessments or certification.
• –Concealment of audit findings, incidents, non-conformities or safety failures.
• –Retaliation against a person who raised a genuine concern.
• –Serious misconduct affecting the integrity of ACOSTS-approved training, assessment, certification or centre approval.

For the avoidance of doubt, ACOSTS is not a police authority or criminal investigation agency. Concerns relating to criminal activity, violence, theft, assault, bribery, corruption, fraud, forged documents or immediate danger should be reported directly to the police, regulator or competent authority.

This policy is not normally intended for:

• –Routine enquiries.
• –General customer service issues.
• –Ordinary complaints about course schedules, fees or communication.
• –Personal employment grievances unrelated to ACOSTS standards or public-interest concerns.
• –Commercial disputes between learners, centres, agents, employers or service providers.
• –Matters that should be handled under the ACOSTS Complaints and Appeals Policy.
• –Matters already being handled by a court, police authority, regulator or statutory body, unless ACOSTS involvement is necessary because the matter affects ACOSTS standards, approval or certification.

If you decide to make a disclosure under this policy, please provide the information in writing so ACOSTS can properly review and assess your concern. Whistle-blowing concerns should be sent to:

If you initially contact ACOSTS by telephone, you may still be asked to provide the concern in writing. Written information helps ACOSTS record, understand, assess and investigate the matter accurately.

Please set out your concern as fully and clearly as possible. Where available, include:

• –Your name and contact details.
• –Whether you want your identity to be treated as confidential.
• –Name of the organisation, centre or individual involved.
• –Country and location of the concern.
• –Course, standard, certificate, approval, audit or assessment involved.
• –Dates, times and places of relevant incidents.
• –Names or roles of people involved.
• –Details of what happened or what you believe may happen.
• –Why you believe the matter is serious or in the public interest.
• –Whether the concern has already been raised with your employer, centre, regulator or another organisation.
• –What response you received, if any.
• –Any supporting documents, photographs, videos, certificates, attendance records, assessment records, emails, messages or other evidence.
• –Whether there is any immediate health, safety, environmental or certification risk.

You do not need to prove the issue before reporting it. However, you should have reasonable grounds for the concern and provide as much relevant information as possible.

ACOSTS will review disclosures received under this policy. The response will depend on whether the disclosure falls within the scope of this policy and the seriousness of the concern raised. ACOSTS will consider whether the concern is within ACOSTS' role, whether another organisation is better placed to deal with the concern, whether there is enough information to assess or investigate the matter, and whether there is an immediate risk to health, safety, the environment, learners, workers, certificate integrity or ACOSTS standards. ACOSTS may decide not to investigate a concern where it is outside scope, unsupported, malicious, repetitive, already resolved, already under authority investigation, or more appropriately handled by another body.

Depending on the concern, ACOSTS may take one or more of the following actions:

• –Make a confidential record of the concern.
• –Add the information to ACOSTS' records for the relevant organisation, centre, provider or individual.
• –Request further information from the reporting person.
• –Review documents, records, certificates, audit files or approval history.
• –Check learner records or certificate validation data.
• –Raise the issue directly with the relevant organisation, if appropriate.
• –Conduct a remote review, desktop review, monitoring review or site audit.
• –Appoint an auditor, investigator, technical expert or reviewer.
• –Require corrective action or preventive action.
• –Increase monitoring of an approved centre or provider.
• –Suspend, restrict, refuse or withdraw approval where justified.
• –Investigate, suspend, cancel or withdraw certificates where appropriate.
• –Notify another body, regulator, authority, employer or law enforcement agency where appropriate and lawful.
• –Close the matter where no further action is appropriate.

Where contact details are provided, ACOSTS will aim to:

• –Acknowledge receipt of your disclosure within five working days.
• –Inform you if further information is required.
• –Consider the concern and decide whether it falls within this policy.
• –Advise, where appropriate, if the matter has been referred to another body or regulator.
• –Provide, where appropriate, a general outline of action taken after consideration of the information provided.

The level of detail ACOSTS can share may be limited due to confidentiality, legal obligations, data protection, safety considerations, commercial sensitivity, ongoing investigation, legal privilege or the rights of other individuals.

If you ask ACOSTS to conceal your identity, ACOSTS will seek to do so as far as reasonably possible. However, confidentiality cannot be guaranteed in all circumstances. Disclosure of your identity may be required by law, by a regulator, by a court, by a competent authority, or may be necessary to investigate the concern properly, protect health and safety, ensure due process, or prevent serious harm. Even where ACOSTS does not disclose your identity, others may be able to infer who raised the concern from the circumstances or details provided. ACOSTS will use discretion when handling such matters.

ACOSTS does not encourage anonymous reporting because it can make proper review or investigation more difficult. Anonymous reports may limit ACOSTS' ability to ask questions, assess credibility, verify facts, obtain evidence or provide updates. However, ACOSTS may still consider anonymous reports where the concern appears serious, credible, evidence-based or indicates a significant risk to health, safety, the environment, learners, workers, certificate integrity or ACOSTS standards. Where possible, individuals are encouraged to provide contact details and request confidentiality rather than report anonymously.

ACOSTS does not tolerate retaliation, victimisation, intimidation, harassment, threats, dismissal, blacklisting, discrimination or unfair treatment against any person who raises a genuine whistle-blowing concern in good faith. Where retaliation is connected with an ACOSTS-approved or applicant organisation, ACOSTS may consider appropriate action, which may include raising the issue with the organisation, requiring corrective action, increasing monitoring, suspending approval, withdrawing approval or notifying relevant authorities.

A person who raises a concern honestly and in good faith will not be treated negatively by ACOSTS simply because the concern is not substantiated. However, knowingly false, malicious, vexatious or deliberately misleading allegations may result in appropriate action, including refusal to consider further reports, notification to relevant parties or legal action where appropriate.

ACOSTS is not a substitute for police, emergency services, regulators or statutory authorities. If the concern involves immediate danger, threat to life, serious injury, violence, assault, theft, bribery, corruption, fraud, forged documents, environmental emergency or criminal conduct, you should report the matter directly to the appropriate police, emergency service, regulator or competent authority. ACOSTS may also report suspected criminal conduct, serious fraud, certificate forgery or safety-critical misconduct to relevant authorities where appropriate and lawful.

ACOSTS will process personal data received under this policy in accordance with its Privacy Policy. Personal data may be used to receive, assess, investigate, record, escalate and resolve whistle-blowing concerns. Personal data may be shared with relevant ACOSTS personnel, regional offices, approved centres, applicant centres, employers, auditors, investigators, technical experts, professional advisers, regulators, authorities or law enforcement where necessary and lawful.

ACOSTS will keep appropriate confidential records of whistle-blowing disclosures, evidence, assessments, actions taken, referrals, outcomes and related communications. Records may be retained for audit, legal, regulatory, quality assurance, certification, centre approval, investigation, safety and governance purposes.

ACOSTS will keep this policy under regular review and may update it from time to time to reflect changes in law, governance, standards, certification processes, centre approval requirements, regional operations or best practice. The latest version will be published on the ACOSTS website.

Whistle-blowing disclosures should be sent to: