Whistleblower Protection Policy
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Purpose
This policy provides a safe, confidential and legally compliant mechanism for reporting misconduct, dishonest, illegal or unethical behaviour within DeadlyScience Ltd (DS). It implements the protections in Part 9.4AAA of the Corporations Act 2001 (Cth) and ASIC Regulatory Guide (RG) 270 and supports ACNC Governance Standard 5 by promoting integrity and accountability across all DS operations.
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Scope
Applies to current and former:
• Directors and Board Committee members;
• Employees, volunteers and secondees;
• Contractors, suppliers and their employees;
• Associates (as defined in s 9, Corporations Act); and
• Relatives or dependants of any of the above.
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Definitions
Term Meaning Whistleblower An eligible person who makes a protected disclosure under this policy or Part 9.4AAA. Reportable Conduct Conduct that is dishonest, fraudulent, corrupt, illegal, a breach of regulation, unethical, or poses danger to the public or financial system. Personal Work-related Grievance Grievance about individual employment that does not have broader public interest implications; not covered by Corporations Act protections but handled via HR Grievance Procedure Eligible Recipient Chair, CEO, Company Secretary, Whistleblower Protection Officer (WPO), Auditor, ASIC, APRA, ACNC, ATO, or lawyer for legal advice. Detrimental Conduct Actual or threatened victimisation, dismissal, demotion, discrimination, harassment, or harm to a Whistleblower. Whistleblower Protection Officer (WPO) Independent person appointed by the Board (ARC Chair or delegate) to oversee reports and safeguard whistleblowers.
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Policy Statements
1. Zero Tolerance for Retaliation – DS prohibits detrimental conduct against any person because of a whistleblower disclosure.
2. Confidentiality – DS protects the identity of whistleblowers, only disclosing with consent or as permitted by law.
3. Impartial Investigation – All disclosures assessed promptly and, where required, investigated by an independent person.
4. Fair Treatment – Persons named in a disclosure are presumed innocent until investigation concludes and are afforded procedural fairness.
5. Regulatory Compliance – DS complies with Corporations Act, ASIC RG 270 and ACNC guidance on whistleblower programs.
6. Accessibility – Multiple reporting channels (internal & external) are available, including an independent 24/7 hotline.
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Reporting Channels
Channel Contact Details Availability Independent Hotline 1800 XXX XXX (operated by IntegrityLine Pty Ltd) example only 24/7 phone & web portal Email whistleblower@deadlyscience.org.au (monitored by WPO only) 24/7 Postal Private & Confidential, PO Box 123, Sydney NSW 2000 (WPO) Anytime Internal Direct report to Chair, CEO, Company Secretary or WPO Business hours External Regulators ASIC, ACNC, ATO, OAIC, SafeWork As per regulator Legal Adviser Personal lawyer for confidential advice As required
Disclosures may be anonymous and still qualify for legal protection.
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What Should Be Reported
• Fraud, theft, corruption, bribery, modern-slavery practices.
• Misuse of donor funds or assets.
• Child safety breaches or cultural-safety violations.
• Serious WHS hazards or environmental harm.
• Privacy or cybersecurity incidents intentionally concealed.
• Any attempt to conceal or destroy evidence related to the above.
Exclusion: Personal employment grievances (pay disputes, interpersonal conflicts) unless reprisal for whistleblowing.
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Investigation Process
Step Action Indicative Timeframe 1. Receipt & Triage WPO logs disclosure, assesses risk of detriment, acknowledges receipt (unless anonymous). 48 h 2. Preliminary Assessment Determine if allegation falls within Reportable Conduct; consult ARC Chair if unclear. 5 d 3. Investigation Plan Assign investigator (independent external if Senior Leadership implicated); establish scope, timeline. 7 d 4. Investigation Gather evidence, interview witnesses, maintain confidentiality. 30 d (target) 5. Outcome Report Findings, recommendations; de-identified summary to ARC & Board. 10 d after investigation 6. Action & Feedback Disciplinary, control improvements; whistleblower advised of outcome (subject to legal limits). Within 14 d 7. Closure & Review Lessons learned logged; ERM and Fraud Control Plan updated. 30 d
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Protection Measures
• Confidentiality – Identity stored in restricted SharePoint file; redacted in reports. • Anonymity – Hotline and web portal allow anonymous reporting; no obligation to reveal identity.
• Anti-Retaliation – Breach constitutes serious misconduct; immediate disciplinary action.
• Support Services – Access to Employee Assistance Program (EAP) for whistleblowers and affected staff.
• Compensation & Remedies – Whistleblower can seek court-ordered compensation for loss due to detriment (s 1317AD).
• Immunity – Protected from civil, criminal or administrative liability for making disclosure (s 1317AA).
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Record-Keeping & Reporting
• Incident log maintained by WPO; restricted access.
• Quarterly anonymised statistics to ARC: number of disclosures, status, themes.
• Annual Report includes statement of whistleblower program effectiveness.
• Serious breaches of child or cultural safety escalated to Board immediately and regulators as required.
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Training & Awareness
Audience Content Frequency All Staff & Volunteers Policy overview, how to report, protections. At induction + biennial refresher Managers Handling disclosures, anti-retaliation responsibilities. Annual Board & ARC Oversight obligations, RG 270 guidance. Biennial
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Roles & Responsibilities
Role Key Duties Board Approve policy; ensure program effectiveness; receive de-identified reports. ARC Oversee WPO; review investigation outcomes; monitor retaliation risk. WPO Receive disclosures; protect identity; manage investigations; maintain log. CEO Encourage speak-up culture; implement remediation; ensure no detriment. Managers Support staff, escalate disclosures, prevent retaliation. All Personnel Report misconduct in good faith; cooperate with investigations.
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Breach of Policy
Retaliation or breach of confidentiality may result in disciplinary action (up to termination), civil penalties and criminal liability under the Corporations Act.
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Review & Continuous Improvement
• Policy reviewed annually or after a material incident or legislative change.
• External effectiveness review every three years in line with RG 270.
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Related Documents
• Fraud & Corruption Control Policy Page 6 of 6 DS-GOP-00.15.01 - Whistleblower Protection Policy
• Enterprise Risk Management Framework & Risk Appetite Policy
• Director Code of Conduct & Fiduciary Duties
• Child Safety & Safeguarding Policy
• Cultural Safety & Indigenous Engagement Framework
• Employee Grievance Resolution Procedure
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Legislative & Guidance References
• Corporations Act 2001 (Cth) – Part 9.4AAA ss 1317AA–AY.
• ASIC Regulatory Guide 270 – Whistleblower Policies (2019).
• ACNC Governance Standard 5 (duties).
• Taxation Administration Act 1953 (Cth) – Part II, Div 2 (Tax whistleblowers).
• Fair Work Act 2009 (Cth) – s 340 protection from adverse action.
• ISO 37002:2021 – Whistleblowing Management Systems (guidance).
- See the full document here.
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