This Whistleblower Notice is drawn from the Neami Group’s Whistleblower Policy. For a copy of the Whistleblower policy, please email email@example.com or phone 03 8691 5300.
The policy rationale is to promote open communication throughout the Neami Group, provide protection to whistleblowers, facilitate the development of practices that reduce the risk of conduct amounting to whistleblower disclosures, and safeguard the reputation, values, and ethics of the Neami Group
A whistleblower disclosure refers to conduct that is:
A Whistleblower can be:
Eligible Recipients are authorised to receive whistleblower disclosures. Eligible Recipients are:
The Whistleblower Protection Officer ensures the protection and fair treatment of the whistleblower. The WPO is responsible for receiving whistleblower disclosures via the email address. The WPO can also receive whistleblower disclosures directly, verbally or in writing. The WPO is also an Eligible Recipient. The WPO is:
A whistleblower disclosure can be made in the following ways:
A whistleblower disclosure can be made in writing and email it to firstname.lastname@example.org. The Whistleblower Protection Officer will receive the emails, and will review the content of the disclosure and determine whether to:
A whistleblower disclosure can be made verbally or in writing to the Whistleblower Protection Officer. The Whistleblower Protection Officer will review the content of the disclosure and determine whether to:
A whistleblower disclosure can be made verbally or in writing to an Eligible Recipient. Eligible Recipients must refer the matter to the Whistleblower Protection Officer.
Any whistleblower disclosures made to other personnel at the Neami Group, such as a Supervisor or Manager, will be referred to the Whistleblower Protection Officer.
A whistleblower disclosure can be made to the Neami Group’s external auditors. However, any disclosures made to the external auditors will be referred to the Whistleblower Protection Officer.
Where disclosures are made to General Counsel and General Counsel considers there to be an actual or perceived conflict of interest, the CEO will be made aware of the disclosure and external legal advice will be sought. Where General Counsel receives a disclosure as a Whistleblower Protection Officer or Eligible Recipient, and an investigation is launched, another individual from the list of Whistleblower Investigation Officers will conduct the investigation.
If the WPO determines a formal investigation is necessary, the WPO will refer the matter to the Whistleblower Investigation Officer or an external investigator (where appropriate) for investigation.
A Whistleblower who makes a report in accordance with the Whistleblower Policy will not be discriminated against or disadvantaged in their employment or engagement with the Neami Group, even if the report is subsequently determined to be incorrect or not substantiated.
The Neami Group strictly prohibits all forms of retaliation against a Whistleblower as a direct result of making a Protected Disclosure. All reasonable steps will be taken to ensure that the Whistleblower will not be subject to any victimisation, discrimination, harassment, demotion, dismissal, threats, prejudice, or any other unfavourable treatment because they made a Protected Disclosure. However, this procedure will not protect the Whistleblower if they are found to have engaged in serious misconduct or illegal conduct in relation to the Reportable Conduct.
A Protected Disclosure can be made anonymously (e.g. through creation of an anonymous email account), and the identity of a Whistleblower cannot be disclosed to a Court or Tribunal without a court order. However, it may be difficult for the Neami Group to properly investigate anonymous reports. If authorities take legal action in relation to the Reportable Conduct, or a disclosure is referred to an external authority (e.g. police, ASIC, or ACNC) early on for formal investigation, it may become necessary for a Whistleblower to identify themselves. If a Whistleblower is required or encouraged to disclose their identity, the Neami Group will continue to ensure that the Whistleblower is protected from retaliation.
The Neami Group will make all reasonable efforts to ensure the identity of a Whistleblower remains confidential throughout the investigation process. The Neami Group will not disclose a Whistleblower’s identity unless:
A report may have serious consequences, including potential damage to the career prospects and reputation of people who are the subject of the Reportable Conduct. Therefore, it is important that those who make a report under this procedure do so honestly and with genuine or reasonable grounds for believing that the information is correct or likely to be correct. Although the motivation of a Whistleblower when making a report will not be considered relevant, if a report is found to be malicious, deliberately misleading or frivolous, the person making the report may be subject to disciplinary action.
The Whistleblower Protection Officer can initiate or coordinate support for employees who have or are in the process of making a report. As a first step, employees can also contact the Neami Group’s employee assistance program, Caraniche, available on 1800 099 444. Further information on Caraniche can be found at www.caraniche.com.au.
A Whistleblower within the Neami Group who is, or considers themselves at risk of being, subjected to detrimental treatment, as a result of making a report on objectively reasonable grounds, should inform an appropriate WPO immediately. The WPO will work with them to take appropriate action, where possible, which may include making recommendations to the Misconduct Governance Committee (e.g. that the concerns be investigated).
The WPO may be unable to assist if the Whistleblower wishes to remain anonymous. Where requests cannot be met, the Whistleblower will be told why.
The Neami Group is committed to ensuring that any person who reports Reportable Conduct, acts as a witness or participates in any way with respect to a report of Reportable Conduct, does not suffer detriment or is not victimised or unfavourably treated. Any reports of such conduct will be thoroughly investigated and, if proven, those who have engaged in such conduct may be subject to disciplinary action, including dismissal.
The Neami Group whistleblowing documentation will be made available through: