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The safe operation of complex socio-technical systems depends on the reporting of safety critical incidents by operators within a system. Through the action of reporting, systems develop the capability as learning organizations to improve human and organizational performance. The research paper will provide a social construction understanding of reporter behavior that is influenced by the safety management system and the context of reporting, within an Air Navigation Service Provider (ANSP) in Africa. A case study methodology was applied with complementing inductive coding and thematic content analysis to explore underlying explanations for underreporting behavior. Four main themes emerged: Knowledge Management, Decentralized Safety Power Distance, Shared Safety Logic and Social Construction of Safety/Efficiency. This broad thematic landscape from the four data sets was reflected against the characteristics set by Complexity Theory to produce a framework that guides the systemic approach to reporting that facilitates organizational learning and greater insight into safety risks and opportunities.