From time to time, you may have a Complaint about personal work-related grievances, service levels, policy decisions, or an employment-related grievance with another person within the organisation, these are not reportable under this policy. These grievance issues may be raised in line with the clubs Grievance Policy with your direct Manager, the organisations General Manager, or the Human Resource Manager directly

This policy also applies to an officer or former officer, an employee or former employee, a member or former member of the Organisation, or a lawyer acting on behalf of a reporting party can disclose to the Organisation or a lawyer acting on behalf of a reporting party can disclose to the Organisation.

Reportable Matters:

The following matters are reportable under this policy:

• • any failures to comply with, or breach of legal or regulatory policy
  • any breach of the organisations code of conduct, policies, and standards
  • criminal activity, bribery, or corruption
  • conduct endangering the health and safety of individuals or the environment
  • conduct causing damage to an individual, the organisation, or the environment
  • dishonest, unethical, or irresponsible behaviour
  • victimisation or harassment that has not been addressed within the organisations grievance policy
  • misleading or deceptive conduct, including conduct or representations which amount to improper or misleading accounting, or financial reporting practices
  • breaches of privacy, or unauthorised use of the organisation’s confidential information
    Information such as dates, times, location, individuals involved, other witnesses, physical evidence (e.g. documents, images), and any other general information may be helpful to assist the organisation in determining how to take appropriate action.

How do I report?

Every person in the Organisation has a role and responsibility in ensuring the Organisation is run ethically and by its internal rules and policies. Where matters related to breaches of internal rules, policies or potential misconduct are identified they should be raised as soon as possible. In instances where a person has concerns about making a report, reports can be made anonymously.

You are encouraged to report to the Whistleblower Protection Officer (WPO) as soon as you know the information. The WPO is the individual within the organisation who has specific whistleblower responsibilities under this Policy. This includes protecting and safeguarding the interests of the reporting individual.

You can report to the WPO, Chairman of the board, by direct contact on – by email at wb@greyhoundsentertainment.com.au

Where practicable, you will be contacted and advised of what action will be undertaken. However, in some instances, communication around the organisation’s response to the report is restrained by confidentiality requirements or other legitimate reasons.

How am I protected?

You will not be penalised or subject to any detriment for reporting under this policy. It is unlawful to cause detriment to you or another person on the belief or suspicion that a report has been, or will be, made, regardless of whether the report was made. The organisation will not tolerate such unlawful behaviour. Anyone engaging in unlawful detrimental conduct may be subject to disciplinary action.
Examples of detrimental conduct include (but are not limited to):

• • dismissal of an employee;
  • injury of an employee in their employment;
  • alteration of an employee’s position or duties to his or her disadvantage;
  • discriminatory behaviour towards the employee;
  • harassment or intimidation of a person;
  • harm and injury to a person, including psychological harm; or
  • damage to a person’s property, reputation, business, or financial position.

You may be entitled to protection from civil liability, criminal liability, and administrative liability in respect of the disclosure. Note that the whistleblower protections do not grant immunity for any potential misconduct you have engaged in that is revealed in the report.

The organisation will maintain the confidentiality of your identity unless the disclosure is authorised under law, or you consent to the disclosure of your identity. Information obtained from you will only be disclosed to the extent reasonably necessary to investigate the matter and the organisation will take all reasonable steps to reduce the risk that your identity will be identified as a result of the disclosure.

It is important to note that reasonable administrative or management activities such as managing your unsatisfactory work performance does not constitute a detriment if the action taken is consistent with the organisation’s performance management process.

Furthermore, an administrative action that is reasonable to protect you from the risk of detriment is not detrimental conduct. For example, the organisation may ask you to perform your duties from another location, reassign you to another role at the same level, or make other modifications to your workplace or the way you perform your work duties.

What happens once a report is made?

All reports of misconduct under this Policy will be dealt with promptly, fairly, and objectively. The organisations response to the report will vary depending on the nature of the report and the amount of information provided. Your report may be addressed and resolved informally or through formal investigation.

If the WPO determines that an investigation is required, the WPO may choose to involve a Whistleblower Investigating Officer (WIP) and brief the WIO or an Independent Third Party to investigate with the objective of locating evidence that either substantiates or refutes the claims of Potential Misconduct. The WPO will monitor the investigation to ensure the confidentiality of the investigation is maintained.

The WIO or third party will investigate promptly and will be fair and independent from any persons to whom the report relates. All employees and contractors must cooperate fully with any investigation. Where appropriate, a person being investigated will be provided with details of the report that involves them (to the extent permitted by law) and be allowed to respond.

The WIO or third Party will gather documents, information, and evidence relating to the report including ensuring that all documentation and information relating to the report is kept secure and protected. The WIO or Third party will draw objective conclusions based on the evidence gathered during the investigation and present findings and recommendations to the WPO. The WPO will determine the appropriate response and necessary action to remediate or act on the investigation findings. The organisation is committed to implementing the findings and recommendations of any investigation to rectify any wrongdoing as far as is practicable in the circumstances.

The WPO will report the findings and actions directly to the Board of the organisation. In cases where the General Manager, the CEO, or a member of the Board has been accused of reportable conduct, or where they have a close personal relationship with the person against whom the accusation is made, they will be excluded from the reporting process.

Document References

Grievance Policy
Performance Management Policy

Definitions

• • Organisation means Greyhound Entertainment
  • Policy means this Whistleblower Policy
  • Potential Misconduct means any suspected or actual misconduct or an improper state of affairs or circumstances concerning the organisation. It also means (but is not limited to) a breach of law or information that indicates a danger to the public or the financial system.
  • Reporting means informing (verbally and/or in writing) the appropriate person identified in the Policy if you have reasonable grounds to suspect that potential wrongdoing has occurred or is occurring in relation to Greyhound Entertainment.
  • “Whistleblower” means the person reporting
  • Whistleblower Investigation Officer (WIO) Is the “HR Manager” means the person who has responsibility for investigating the report of Potential Misconduct
  • Whistleblower Protection Officer (WPO) is the “Chairman of the Board” means the person who has specific whistleblower responsibilities under this Policy including the protection and safeguarding of the interests of the reporting individual

Communication

The organisation will ensure that:

• • this policy is easily accessible in the staff room
  • employees are empowered to actively contribute and provide feedback to this policy
  • employees are notified of any changes to this policy

Monitoring and Review

The organization will review this policy annually. The effectiveness of this policy will be assessed through the;

• • feedback from workers
  • review of the policy by management to determine if objectives have been met and to identify barriers and enablers to ongoing policy implementation

Version: 2
Prepared by: HR Manager
Approved by: General Manager on 01/03/2023
Next review date: 01/03/2024