Purpose and Commitment

We are committed to maintaining the highest standards of integrity, ethical conduct, and legal compliance in all aspects of our business operations. This Speak Up Policy demonstrates our commitment to creating and maintaining a workplace culture where all employees, contractors, and stakeholders feel safe and supported to raise concerns about potential misconduct, illegal activities, or other matters that may affect our organization or the broader community [1].

Our organization recognizes that employees and other stakeholders are often the first to become aware of potential problems, misconduct, or areas where our standards may not be being met. We value and encourage the reporting of such concerns as an essential component of our risk management framework and our commitment to continuous improvement [2].

This policy reflects our belief that speaking up about concerns is not only a right but also a responsibility that contributes to maintaining our organizational integrity and protecting the interests of our employees, customers, shareholders, and the broader community. We are committed to ensuring that individuals who raise concerns in good faith are protected from reprisal and that all concerns are investigated thoroughly and fairly [3].

Our commitment to encouraging and protecting those who speak up is aligned with our core values and our legal obligations under Australian whistleblower protection laws. We recognize that effective speak up mechanisms are essential for identifying and addressing potential problems before they escalate and for maintaining stakeholder trust and confidence in our organization [4].

We are committed to regularly reviewing and improving our speak up processes to ensure they remain effective, accessible, and aligned with best practices and legal requirements. This includes providing appropriate training and support to employees, maintaining robust investigation procedures, and ensuring that lessons learned from speak up reports are incorporated into our business practices [5].

This policy applies to all forms of speaking up, including formal whistleblower disclosures under the Corporations Act 2001, internal reports of misconduct or policy violations, and informal raising of concerns through management channels. We are committed to treating all forms of speaking up with appropriate seriousness and providing consistent protection and support to those who raise concerns [6].

Scope and Application

This Speak Up Policy applies to all employees, directors, contractors, consultants, suppliers, customers, and other stakeholders who have interactions with our organization. The policy covers concerns raised about any aspect of our business operations, including conduct by our employees, contractors, suppliers, or other parties acting on our behalf [7].

The policy applies to concerns raised through any channel, whether formal or informal, and regardless of whether the concern relates to actual misconduct, suspected misconduct, or potential risks that may lead to misconduct. We encourage the reporting of concerns at the earliest possible stage, recognizing that early intervention is often more effective than addressing problems after they have escalated [8].

This policy covers concerns raised by current and former employees, as well as external parties who may have knowledge of potential misconduct or other issues affecting our organization. We recognize that valuable information about potential problems may come from various sources, and we are committed to providing appropriate channels and protections for all legitimate concerns [9].

The policy applies to conduct that occurs in any location where our business is conducted, including our offices, customer sites, supplier facilities, and any other locations where our employees or representatives are acting on behalf of our organization. It also covers conduct that occurs outside of work hours if it has the potential to affect our business operations or reputation [10].

This policy should be read in conjunction with our other policies and procedures, including our Code of Conduct, Anti-Discrimination and Harassment Policy, Complaint Handling Policy, and Privacy Policy. Where there are overlaps between policies, we will ensure that the most protective provisions apply and that individuals are not disadvantaged by choosing one reporting channel over another [11].

The policy covers both disclosures that may qualify for protection under the Corporations Act 2001 whistleblower provisions and other forms of speaking up that may not meet the technical requirements for statutory whistleblower protection but are nonetheless valuable for our organization and deserving of appropriate protection and response [12].

Legal Framework

Our Speak Up Policy is designed to comply with and exceed the requirements of Australian whistleblower protection laws, particularly the provisions of the Corporations Act 2001 that provide protection for eligible whistleblowers who make qualifying disclosures about corporate misconduct [13].

The Corporations Act 2001 provides comprehensive protection for whistleblowers who disclose information about misconduct by corporations, including protection from civil, criminal, and administrative liability, protection from reprisal, and rights to compensation for loss or damage suffered as a result of reprisal. These protections apply to disclosures made to specified recipients about disclosable matters [14].

Disclosable matters under the Corporations Act include misconduct or an improper state of affairs in relation to the corporation, conduct that constitutes an offense against Commonwealth law punishable by imprisonment for 12 months or more, conduct that constitutes an offense against any law of the Commonwealth punishable by a penalty of 60 penalty units or more, and conduct that represents a danger to the public or the financial system [15].

Eligible whistleblowers under the Act include current and former employees, officers, contractors, suppliers, associates, and relatives or dependents of these individuals. The Act specifies that disclosures must be made to eligible recipients, including officers or senior managers of the corporation, auditors, ASIC, APRA, or prescribed Commonwealth authorities [16].

In addition to the Corporations Act provisions, our policy is designed to comply with other relevant legislation including the Fair Work Act 2009, which provides protection against adverse action for employees who make complaints or participate in proceedings, and various state and territory laws that may provide additional protections for whistleblowers [17].

Our policy also reflects best practice guidance from regulatory authorities including ASIC and APRA, as well as recommendations from parliamentary inquiries and other authoritative sources on effective whistleblower protection. We are committed to maintaining our policy in accordance with evolving legal requirements and best practices [18].

We recognize that legal compliance represents a minimum standard and that effective speak up mechanisms require going beyond mere compliance to create a culture where speaking up is genuinely encouraged and protected. Our policy is designed to provide comprehensive protection and support that meets or exceeds legal requirements [19].

What is Speaking Up

Speaking up refers to the act of raising concerns, reporting misconduct, or providing information about potential problems that may affect our organization, our stakeholders, or the broader community. Speaking up can take many forms, from informal conversations with supervisors to formal whistleblower disclosures to regulatory authorities [20].

We encourage speaking up about any matter that causes concern, regardless of whether it clearly constitutes misconduct or whether the person raising the concern has complete information about the situation. We recognize that individuals may have partial information or may be uncertain about whether their concerns are justified, and we prefer to receive and assess concerns rather than have them go unreported [21].

Speaking up includes reporting actual misconduct that has been observed or experienced, as well as reporting suspected misconduct based on reasonable grounds for suspicion. It also includes reporting potential risks or vulnerabilities that could lead to misconduct if not addressed, and raising concerns about organizational practices or policies that may be inadequate or inappropriate [22].

We distinguish between speaking up in good faith, which we encourage and protect, and malicious or vexatious reporting, which we do not tolerate. Good faith reporting means that the person raising the concern genuinely believes that the information they are providing is true and that they are raising the concern for legitimate purposes rather than to cause harm or gain personal advantage [23].

Speaking up can be done through various channels and in various ways, including verbal reports, written reports, anonymous reports, and reports made through third parties. We are committed to providing multiple accessible channels for speaking up and to responding appropriately regardless of the channel used or the manner in which concerns are raised [24].

We recognize that speaking up can be difficult and may involve personal and professional risks for those who raise concerns. We are committed to making speaking up as safe and supported as possible, while also ensuring that concerns are investigated thoroughly and that appropriate action is taken based on investigation findings [25].

Types of Concerns We Want to Hear About

We encourage speaking up about a wide range of concerns that may affect our organization, our stakeholders, or the broader community. While we cannot provide an exhaustive list of all matters that may be appropriate for speaking up, the following categories provide guidance on the types of concerns we want to hear about [26].

Financial and Accounting Misconduct includes concerns about fraudulent financial reporting, misappropriation of funds, unauthorized transactions, conflicts of interest involving financial benefits, tax evasion, and other matters that may affect the accuracy or integrity of our financial records or reporting [27].

Legal and Regulatory Violations encompasses concerns about violations of any laws or regulations applicable to our business, including consumer protection laws, environmental regulations, workplace safety requirements, licensing obligations, and any other legal requirements that govern our operations [28].

Workplace Safety and Health Issues includes concerns about unsafe working conditions, failure to follow safety procedures, inadequate safety training or equipment, exposure to hazardous substances, and any other matters that may pose risks to the health and safety of our employees, contractors, customers, or members of the public [29].

Discrimination, Harassment, and Bullying covers concerns about unfair treatment based on protected characteristics, sexual harassment, workplace bullying, victimization, and other forms of inappropriate workplace behavior that may create hostile or discriminatory work environments [30].

Ethical Misconduct and Conflicts of Interest includes concerns about violations of our Code of Conduct, inappropriate use of company resources, conflicts of interest that have not been properly disclosed or managed, acceptance of inappropriate gifts or benefits, and other conduct that may compromise our ethical standards [31].

Customer and Consumer Issues encompasses concerns about misleading or deceptive conduct toward customers, failure to meet consumer protection obligations, product safety issues, inadequate service delivery, and other matters that may affect customer rights or interests [32].

Environmental and Sustainability Concerns includes concerns about environmental damage, failure to comply with environmental regulations, inadequate environmental management practices, and other matters that may affect environmental sustainability or community wellbeing [33].

Supplier and Contractor Misconduct covers concerns about inappropriate conduct by suppliers, contractors, or other third parties acting on our behalf, including corruption, poor working conditions, environmental violations, and other matters that may reflect on our organization or affect our stakeholders [34].

Data Protection and Privacy Violations includes concerns about unauthorized access to personal information, data breaches, failure to comply with privacy laws, inappropriate use of customer or employee data, and other matters that may affect data security or privacy rights [35].

Systemic Issues and Risk Management Failures encompasses concerns about inadequate risk management systems, failure to learn from previous incidents, systemic problems that may affect multiple areas of our business, and other matters that may indicate broader organizational weaknesses [36].

How to Speak Up

We provide multiple channels for speaking up to ensure that all individuals can find a method that is comfortable and appropriate for their circumstances. We encourage individuals to use the channel that they feel most comfortable with, and we are committed to providing consistent protection and response regardless of the channel chosen [37].

Direct Supervisor or Manager represents the most immediate channel for raising concerns and is often appropriate for workplace issues, operational problems, or other matters that can be addressed at the local level. We encourage open communication between employees and their supervisors and provide training to managers on how to receive and respond to concerns appropriately [38].

Human Resources Department provides a channel for concerns that may not be appropriate to raise with direct supervisors, including concerns about management conduct, workplace relations issues, policy violations, and other matters that require specialized expertise or independence from operational management [39].

Senior Management including our CEO, General Manager, and other senior executives, provides a channel for serious concerns that require senior-level attention, including concerns about systemic issues, significant misconduct, or matters that may have major implications for our organization [40].

Anonymous Reporting Mechanisms are available for individuals who prefer not to identify themselves when raising concerns. This includes anonymous email addresses, suggestion boxes, and third-party reporting services that can receive and forward concerns while protecting the identity of the reporter [41].

External Reporting Channels include regulatory authorities such as ASIC, Fair Work Ombudsman, and other relevant agencies that have jurisdiction over specific types of misconduct. We provide information about relevant external channels and support individuals who choose to report externally [42].

Third-Party Reporting Services provide independent channels for raising concerns, including telephone hotlines, online reporting systems, and other services operated by external organizations that specialize in receiving and managing workplace concerns [43].

When speaking up, individuals are encouraged to provide as much relevant information as possible, including details about what happened, when it happened, who was involved, any witnesses, and any evidence that may be available. However, we recognize that individuals may not have complete information, and we encourage reporting even when information is limited [44].

We provide guidance and support to help individuals determine the most appropriate channel for their concerns and to prepare their reports effectively. This includes providing templates, checklists, and other resources that can help individuals organize their information and communicate their concerns clearly [45].

Protection from Reprisal

We are committed to protecting individuals who speak up in good faith from any form of reprisal, retaliation, or adverse treatment as a result of their reporting. This protection is fundamental to maintaining an effective speak up culture and is required by law for qualifying whistleblower disclosures [46].

Prohibited Reprisal Actions include dismissal, demotion, harassment, discrimination, disciplinary action, threats, intimidation, ostracism, and any other action that may cause detriment to an individual because they have spoken up or are suspected of having spoken up [47].

Broad Protection Scope extends to protection from reprisal by any person within our organization, including colleagues, supervisors, managers, and senior executives. Protection also extends to reprisal by external parties such as suppliers, contractors, or customers, and we will take appropriate action to address any such reprisal [48].

Immediate Protection Measures are implemented as soon as we become aware that someone has spoken up, including monitoring for signs of reprisal, providing support and resources to the reporter, and taking preventive measures to minimize the risk of adverse treatment [49].

Investigation of Reprisal is conducted promptly and thoroughly whenever allegations of reprisal are made or suspected. Reprisal investigations are conducted independently from investigations of the underlying concerns and may result in disciplinary action against those responsible for reprisal conduct [50].

Remedial Action is taken to address any reprisal that is found to have occurred, including reversing adverse actions where possible, providing compensation for losses suffered, implementing measures to prevent further reprisal, and taking disciplinary action against those responsible [51].

Support During Proceedings is provided to individuals who speak up and may be involved in investigation processes, legal proceedings, or other activities related to their concerns. This support may include legal assistance, counseling services, workplace adjustments, and other measures to minimize the impact of speaking up [52].

We recognize that protection from reprisal must be genuine and effective to encourage speaking up. We regularly review our protection measures and seek feedback from those who have spoken up to ensure that our protections are working effectively in practice [53].

Confidentiality and Anonymity

We are committed to protecting the confidentiality of individuals who speak up and maintaining appropriate confidentiality throughout investigation and response processes. We recognize that confidentiality is essential for encouraging speaking up and for protecting those who raise concerns from potential adverse consequences [54].

Confidentiality Protections include limiting access to information about speak up reports to those who need to know for investigation and response purposes, implementing secure systems for storing and managing confidential information, and providing training to staff about confidentiality obligations [55].

Identity Protection involves taking all reasonable steps to protect the identity of individuals who speak up, including using code names or numbers in investigation files, limiting the circulation of identifying information, and ensuring that investigation processes do not inadvertently reveal the identity of reporters [56].

Anonymous Reporting Options are available for individuals who prefer not to identify themselves when raising concerns. We provide multiple channels for anonymous reporting and have systems in place to receive, investigate, and respond to anonymous concerns effectively [57].

Limitations on Confidentiality may apply in certain circumstances, including where disclosure is required by law, where disclosure is necessary for effective investigation, where disclosure is required to protect safety, or where the reporter consents to disclosure. We will always discuss any potential limitations with reporters before proceeding [58].

Communication About Investigations is managed carefully to protect confidentiality while ensuring that appropriate stakeholders are informed about investigation progress and outcomes. We use aggregated reporting and other techniques to share information about speak up trends without compromising individual confidentiality [59].

Record Management includes implementing secure systems for storing speak up records, limiting access to authorized personnel, and ensuring that records are retained and disposed of in accordance with legal requirements and best practices [60].

We recognize that maintaining confidentiality can be challenging, particularly in small organizations or when investigating specific incidents. We are committed to being transparent with reporters about any confidentiality limitations and working with them to find appropriate ways to proceed [61].

Investigation Process

We have established comprehensive investigation procedures to ensure that all speak up concerns are assessed and investigated thoroughly, fairly, and promptly. Our investigation process is designed to be independent, objective, and proportionate to the nature and seriousness of the concerns raised [62].

Initial Assessment is conducted for all speak up reports to determine the appropriate response, including whether formal investigation is required, what resources should be allocated, who should conduct the investigation, and what timeframes are appropriate [63].

Investigation Planning involves developing a detailed plan for investigating concerns, including identifying key issues to be investigated, determining what evidence needs to be gathered, identifying relevant witnesses, and establishing investigation timelines and milestones [64].

Evidence Gathering includes collecting and analyzing all relevant information, including documents, electronic records, physical evidence, and witness statements. We use appropriate forensic and investigative techniques to ensure that evidence is gathered thoroughly and preserved properly [65].

Witness Interviews are conducted in a professional and respectful manner, with appropriate support provided to witnesses and clear explanations of the investigation process and confidentiality protections. We ensure that all relevant witnesses have the opportunity to provide their perspective [66].

Independent Investigation is ensured through appropriate governance structures, including using external investigators where necessary, implementing conflict of interest management procedures, and ensuring that investigators have appropriate independence from the subject matter and individuals involved [67].

Fair Process includes providing appropriate opportunities for all parties to present their case, ensuring that allegations are put to relevant individuals for response, and applying principles of natural justice throughout the investigation process [68].

Investigation Reporting involves preparing comprehensive reports that document investigation findings, analyze evidence objectively, reach appropriate conclusions, and recommend suitable actions based on the findings [69].

Timely Resolution is prioritized through establishing clear timeframes for investigation activities, providing regular progress updates to relevant parties, and escalating issues that may cause delays or require additional resources [70].

Support and Resources

We are committed to providing comprehensive support and resources to individuals who speak up, recognizing that raising concerns can be stressful and may have personal and professional implications for those involved [71].

Emotional and Psychological Support is available through our Employee Assistance Program, which provides confidential counseling services, stress management resources, and other mental health support services. We recognize that speaking up can be emotionally challenging and are committed to providing appropriate support [72].

Legal Support and Advice may be provided to individuals who speak up, particularly in cases involving potential legal proceedings or where individuals may face legal risks as a result of their reporting. This may include access to legal advice, representation, or other legal support services [73].

Workplace Support includes making reasonable adjustments to work arrangements where necessary to protect individuals who have spoken up, providing flexible working arrangements during investigation periods, and ensuring that individuals are not disadvantaged in their employment as a result of speaking up [74].

Financial Support may be available in appropriate circumstances, including reimbursement of reasonable expenses incurred as a result of speaking up, compensation for losses suffered due to reprisal, and other financial assistance where justified [75].

Career Protection involves ensuring that individuals who speak up are not disadvantaged in terms of career progression, performance assessment, training opportunities, or other employment-related matters. We monitor the career progression of individuals who speak up to ensure they are not adversely affected [76].

Communication and Updates are provided to individuals who speak up to keep them informed about investigation progress, outcomes, and any actions taken as a result of their concerns. We recognize the importance of closing the loop with those who raise concerns [77].

Peer Support Networks may be established to provide additional support to individuals who speak up, including connecting them with others who have had similar experiences and providing opportunities for shared learning and mutual support [78].

Roles and Responsibilities

Clear roles and responsibilities are essential for ensuring that our Speak Up Policy is implemented effectively and that all stakeholders understand their obligations and expectations [79].

Senior Management has ultimate responsibility for creating and maintaining a culture that encourages speaking up, ensuring that appropriate resources are allocated to speak up processes, and demonstrating leadership commitment to protecting those who raise concerns [80].

Board of Directors provides oversight of speak up processes, reviews reports on speak up activities and outcomes, and ensures that appropriate governance structures are in place to support effective speak up mechanisms [81].

Human Resources is responsible for implementing speak up procedures, providing support to individuals who speak up, coordinating investigation activities, and ensuring that appropriate training and awareness programs are delivered [82].

Managers and Supervisors have responsibility for creating safe environments for speaking up, responding appropriately to concerns raised with them, supporting employees who speak up, and ensuring that no reprisal occurs within their areas of responsibility [83].

All Employees have responsibility for speaking up about concerns they become aware of, supporting colleagues who speak up, cooperating with investigation processes, and maintaining confidentiality as required [84].

Investigation Personnel are responsible for conducting thorough, fair, and timely investigations, maintaining appropriate confidentiality, following established procedures, and providing clear and objective reports on their findings [85].

Legal and Compliance Teams provide advice on legal requirements, support investigation processes, ensure compliance with regulatory obligations, and provide guidance on appropriate responses to speak up concerns [86].

Training and Awareness

Comprehensive training and awareness programs are essential for ensuring that all stakeholders understand their rights and responsibilities under our Speak Up Policy and feel confident about raising concerns when necessary [87].

General Awareness Training is provided to all employees and covers the importance of speaking up, the types of concerns we want to hear about, available reporting channels, protection from reprisal, and support resources available [88].

Manager Training provides additional guidance to supervisors and managers on how to receive and respond to concerns, how to create environments that encourage speaking up, how to recognize and prevent reprisal, and how to support employees who raise concerns [89].

Specialized Training is provided to personnel with specific roles in speak up processes, including investigation personnel, human resources staff, and senior management, covering technical skills, legal requirements, and best practices [90].

Regular Refresher Training ensures that knowledge and skills remain current and that changes to policies, procedures, or legal requirements are communicated effectively to all relevant personnel [91].

Communication Campaigns raise awareness of speak up processes through various channels including newsletters, intranet articles, team meetings, and other communication mechanisms that reach all employees and stakeholders [92].

Feedback and Evaluation processes assess the effectiveness of training and awareness programs and identify opportunities for improvement based on participant feedback and speak up activity levels [93].

Monitoring and Review

Regular monitoring and review of our Speak Up Policy and processes ensures that they remain effective, current, and aligned with best practices and legal requirements [94].

Performance Monitoring includes tracking key metrics such as the number of concerns raised, investigation timeframes, resolution outcomes, and satisfaction levels of those who speak up [95].

Regular Policy Review involves annual assessment of policy effectiveness, consideration of changes in legal requirements, incorporation of lessons learned from speak up cases, and updates based on best practice developments [96].

Stakeholder Feedback is sought from employees, managers, and others involved in speak up processes to identify strengths and areas for improvement in our policies and procedures [97].

External Benchmarking compares our speak up processes with industry best practices and regulatory guidance to ensure that we maintain high standards and identify opportunities for enhancement [98].

Continuous Improvement involves implementing changes based on monitoring results, feedback, and best practice developments to ensure that our speak up processes remain effective and supportive [99].