Whistleblower Policy

1. Policy Overview

[Business Name] (the Company) is committed to the highest standards of ethical conduct and accountability. We encourage a culture of openness and transparency. This Whistleblower Policy outlines how you can report serious wrongdoing (disclosable conduct) within the Company. It explains how the Company will protect you if you make a report.

2. Purpose

The purpose of this policy is to:

• Allow you to report disclosable conduct without fear of victimisation or reprisal.
• Provide a clear process for making disclosures.
• Ensure the Company investigates disclosures properly.
• Ensure the Company complies with the Corporations Act 2001 (Cth) and other relevant laws.

3. Scope

This policy applies to:

• All employees, contractors, and officers of [Business Name].
• Suppliers and people who provide services to the Company.
• Anyone who has a business relationship with the Company.

4. Who Can Make a Disclosure

You can make a disclosure if you are an eligible whistleblower. This includes:

• Current employees.
• Former employees.
• Contractors and their employees.
• Officers of the Company.
• Relatives or dependants of the above individuals.

5. What is Disclosable Conduct

You may report conduct if you have reasonable grounds to suspect it involves:

• Misconduct or an improper state of affairs within the Company.
• A breach of the law by the Company or an officer.
• A criminal offence by the Company or an officer.
• Danger to the public or the environment.
• Conduct that represents a danger to the financial stability of the Company.
• Conduct that is an offence against the Taxation Administration Act 1953 (Cth).

6. How to Make a Disclosure

You can make a disclosure in writing or verbally. You should provide as much detail as possible, including:

• The names of the people involved.
• The dates and locations of the conduct.
• Any evidence you have (emails, receipts, photos).

Internal Contacts: You can report to:

• [Name of Internal Contact Person], Job Title: [Job Title], Phone: [Phone Number], Email: [Email Address].
• [Name of Alternative Contact Person], Job Title: [Job Title], Phone: [Phone Number], Email: [Email Address].

External Contacts: If you do not want to report internally, you can contact:

• [External Legal Advisor Name]: [Phone Number].
• [Industry Association Name]: [Phone Number].
• ASIC: 1300 300 630.
• ATO: 1800 060 062.

7. Anonymous Disclosures

You may choose to remain anonymous. The Company will still investigate your disclosure. However, please note that anonymity may make it harder for us to investigate thoroughly.

8. Protection of Whistleblowers

[Business Name] guarantees that:

• We will protect your identity. We will not disclose your identity without your consent unless required by law.
• We will not take detrimental action against you for making a disclosure. Detrimental action includes dismissal, injury, demotion, or discrimination.
• We will protect you from civil and criminal liability in relation to the disclosure.

9. Investigation Process

When we receive a disclosure:

1. [Name of Investigation Officer] will assess the disclosure within [Number] days.
2. If the disclosure qualifies, we will start an investigation.
3. We may appoint an external investigator to ensure impartiality.
4. We will aim to finish the investigation within [Number] days.
5. We will keep you informed of the progress where possible.

10. Outcomes

If we find the disclosable conduct is true, we will take action. This may include:

• Disciplinary action against the person involved.
• Referral to law enforcement agencies.
• Changes to Company policies to prevent it happening again.

11. Legal Immunity

You have legal immunity under the Corporations Act 2001 (Cth) for making a disclosure. The Company will take all reasonable steps to protect you.

12. Breach of this Policy

If the Company or an officer victimises a whistleblower, they may face civil and criminal penalties. This includes fines and imprisonment.

13. Policy Review

We will review this policy annually to ensure it remains effective.

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[Date] [Director/Owner Signature] [Director/Owner Name]