Whistleblower Policy

Good Ancestors Policy Ltd. ("us", "we" or the "Company") ABN: 23 664 195 484

Purpose

We want people to speak up when something is wrong. This policy explains how you can raise a serious concern about the Company, and how we protect you when you do.

Who this applies to

This policy applies to everyone who might need to raise a concern about us, and everyone involved in handling one: our directors and officers, employees and contractors, suppliers, and the people who work with us across the programs and projects we run or administer. Who is legally protected is broader (see "Who is protected" below).

Definitions

The policy

Who is protected

Under the whistleblower protection legislation, an eligible whistleblower can be someone who is or was:

• an officer or employee of the charity
• an individual or an employee of a person that supplies services or goods to the entity (including volunteers)
• an individual who is an associate of the entity
• a relative or dependant of any of the above, or a dependant of the spouse of any of the above
• an individual prescribed by the Regulations as being an eligible whistleblower.

An eligible whistleblower can remain anonymous and still qualify for protection.

What is covered ("disclosable matters")

This policy covers a genuine concern that we, or an officer or employee of ours, has engaged in misconduct or an improper state of affairs. Examples include:

• fraud, theft, bribery or corruption;
• illegal conduct;
• serious financial irregularity, or misuse of charity or grant funds;
• a danger to the public or to the financial system;
• a breach of the Corporations Act 2001, the ASIC Act 2001, or other laws covered by the whistleblower regime; or
• conduct that could cause harm to people, or represents a serious risk to us.

You do not need proof. A reasonable suspicion is enough. If you honestly and reasonably believe something is wrong, you are protected even if it turns out you were mistaken. You are not protected if you knowingly make a false report.

Disclosures can be anonymous. You do not have to give your name, and you can stay anonymous throughout, including during any investigation. It helps if we can contact you (even through an anonymous channel) so we can ask follow-up questions.

Personal work-related grievances are different. A complaint that is only about your own employment situation is usually not a disclosable matter, and should go through our grievance process instead. If you are unsure, raise it anyway and we will help you find the right path. Some work-related matters are still covered here, for example if they involve detriment for whistleblowing or a breach of the law.

Who you can tell ("eligible recipients")

To qualify for protection, a whistleblower must make their disclosure to an eligible recipient:

• the Australian Securities and Investment Commission (ASIC)
• the Australian Prudential Regulatory Authority (APRA)
• a Commonwealth body nominated for this purpose in the Regulations (this does not include the ACNC)
• a legal practitioner, if someone is seeking legal advice about whether the protections will apply to them
• an officer (including company directors) or senior manager of the charity in question
• an auditor or member of the audit team for the charity
• an actuary of the charity (mainly relevant for banking, insurance, and superannuation entities)
• a person that the charity has authorised to receive a disclosure (this can include a person external to the charity).

You never have to report to a person your concern is about. You can go to any other senior manager or director within the Company, or straight to an external party to bypass anyone the report involves.

Our current senior management and directors are listed on our website and our directors are listed on the ACNC Register.

You can also make anonymous disclosures using this form.

Public interest and emergency disclosures

In limited circumstances, the law also protects a disclosure made to a member of parliament or a journalist:

• a public interest disclosure: you have already reported the matter to ASIC, at least 90 days have passed, you don't have reasonable grounds to believe it's being dealt with, and you've given ASIC written notice of your intention; or
• an emergency disclosure: there is a substantial and imminent danger to someone's health or safety or to the environment, and you've given ASIC written notice.

Confidentiality

We protect your identity. Once you make a disclosure that qualifies for protection, it is illegal for anyone to reveal your identity, or information likely to identify you, except in limited circumstances the law allows. Those limited circumstances include disclosure to ASIC, APRA, the ATO or the police, to a legal practitioner for advice, or with your consent.

We may need to investigate the substance of what you raised, and that can involve sharing some details. When we do, we will take reasonable steps to reduce the risk that you are identified, such as removing identifying information, restricting who is involved, and reminding everyone handling the matter of their confidentiality duties.

Protection from detriment

It is unlawful for anyone to cause you detriment, or threaten to, because you have made (or are believed to have made) a disclosure. That includes dismissal, harassment, bullying, demotion, discrimination, or any other disadvantage.

If this happens, tell an eligible recipient straight away. The law provides remedies, which can include compensation, reinstatement, and orders against the person responsible. Victimising a whistleblower can also be a criminal offence and can expose the individual and the organisation to penalties. We treat any victimisation as a serious breach of this policy and our Code of Conduct.

We will also take reasonable steps to protect you while a matter is being handled, which may include adjusting reporting lines or work arrangements.

Fair treatment of the person a report is about

A disclosure is an allegation, not a finding. Anyone named in a report is treated fairly. They are presumed innocent, told of the substance of any allegation against them at an appropriate time (in a way that protects the whistleblower's identity), given a chance to respond, and supported through the process.

Roles and responsibilities

What to do / how it works

1. Raise it. Contact any eligible recipient listed above, through any channel that suits you, including the anonymous option. You can share as much or as little as you are comfortable with.
2. We acknowledge it. Where we can contact you (even anonymously), we acknowledge your disclosure promptly.
3. We assess it. We work out whether it is a disclosable matter under this policy, a personal grievance for another process, or something else, and what needs to happen next.
4. We investigate fairly. Where an investigation is needed, it is objective, confidential and fair to everyone involved. We may use an independent investigator for serious matters.
5. We protect you. We take steps to protect your identity and to shield you from detriment throughout.
6. We give feedback. Where we can, we let you know the outcome or progress, subject to confidentiality and privacy obligations.
7. We fix and learn. We act on findings and review our controls so problems are less likely to happen again.

Making sure people know about it

Because the people this policy protects go beyond current staff we:

• publish it on our website;
• save it in our staff shared drives;
• cover it at staff onboarding;
• re-share it with the team periodically.

The Company Secretary keeps it current and available, including to former staff, contractors and others on request.