Whistleblower Policy

Whistleblower Policy Statement

At MetLife it is unacceptable for our people to engage in any form of misconduct and we actively encourage our people to speak up about wrongdoing.  Sometimes people may be concerned that speaking up could lead to being identified or experience repercussions for reporting misconduct.  We want people to feel safe and have put in place a Whistleblower Policy to encourage and support individuals to report wrongdoing or misconduct, and to ensure we uphold both professional and personal standards of conduct in line with the culture at MetLife. 

Please note, the legal definition of ‘misconduct’ can be difficult to understand. It can include a broad range of activities, such as not meeting our legal obligations or dishonest, fraudulent, corrupt or unethical behaviour.  If you want help to understand if the conduct you have observed meets the definition, contact us on our Ethics and Fraud Helpline on a confidential basis.

Who is a whistleblower under the MetLife Whistleblower Policy?

Unfortunately, not everyone who reports something they think is ‘misconduct’ can be captured under the law or classified as ‘whistleblower’ under our Whistleblower Policy. 

Under our policy, a whistleblower includes a list of people that has been based on legal requirements.  For example, a person might be a whistleblower if they are, or have been an employee of MetLife or a MetLife supplier.  If you want to know if you fit the definition of a whistleblower, contact us on our Ethics and Fraud Helpline on a confidential basis.

How do I report misconduct?

If you become aware that we have engaged, or may have engaged, in misconduct, you can report this via our Ethics and Fraud Helpline on a confidential basis.

The person who answers your call or reads your email does not work for MetLife.  We have engaged an independent highly skilled specialist to confidentially engage with you to collect as much information as you are willing to share about the misconduct you know about which involves MetLife. Ultimately it will be up to you to decide what you tell us.

You can even contact your people leader, Risk and Compliance or Legal just to ask questions about how our process works. 

While MetLife encourages you to raise any misconduct with us, there are other ways to access whistleblower protections in the law: raise your concerns in a compliant way with your lawyer, the Australian Securities and Investments Commission (ASIC), the Australian Prudential Regulation Authority, a journalist or a parliamentarian. 

If you raise misconduct via one of these options outside of MetLife, you will need to follow specific steps set out in the law in order to access whistleblower protections. ASIC has included information in INFO 239 “How ASIC handles whistleblower reports” and INFO 238 “Whistleblower rights and protections” on how to report misconduct using these non-MetLife options. You should also seek advice from your lawyer on how to proceed.

What does MetLife do with reports of misconduct?

What we do with reports of misconduct really depends on the type of behaviour that you report and who you are.  Regardless of whether you meet the definition of whistleblower, we will carefully listen to your report and advise you what your options are.  We will assess the allegation that is reported and decide whether a formal internal investigation of misconduct is required.

We may update you, but we cannot promise that we will inform you of our findings as we treat whistleblower reports separately to complaints raised by our customers.  We may not get back to you for a number of reasons, for example, to preserve your anonymity and/or of the persons included in the alleged misconduct who may not have a chance to respond.

We may not reply to you in order to reduce the risk of retaliation against you or others which MetLife prohibits under any circumstances.

What protections are available to a whistleblower?

If you qualify as a whistleblower under our Whistleblower Policy, these protections are available to you in our policy and under the law:

Right to remain anonymous

While you are encouraged to share your identity when making a disclosure of misconduct, as it will make it easier for MetLife to address your disclosure, you are not required to do so. There may be some practical limitations in investigating if you do not share your identity.

Retaliation is prohibited

MetLife does not tolerate retaliation for making a report of misconduct. MetLife prohibits employees from engaging in any form of retaliation against anyone for raising concerns and reports of retaliation will be investigated and addressed, as appropriate.  If you believe you have experienced retaliation, report it immediately using the Ethics and Fraud Helpline.

Civil liability and criminal liability

A person who meets the criteria of a whistleblower is protected from civil, criminal and administrative liability.