Whistle-blower Policy

Hear and Say Whistle-blower Policy

Hear and Say holds itself to high standards of conduct and ethical behaviour. To achieve this expectation requires a transparent environment that supports operational feedback and a commitment to hearing both constructive and positive feedback.

Hear and Say supports and encourages the reporting of any matters that contravene Hear and Say’s policies or standards and any contravention of the law. Hear and Say will take relevant steps to investigate Whistle-blower’s concerns and reports, whilst remaining sensitive to those who have reported the activity as well as anyone subject to the report content.

Whistle-blowers are to be protected from personal detriment or reprisal.

Scope

What is a Whistle-blower?

A Whistle-blower is someone with inside knowledge of an organisation who reports misconduct or dishonest or illegal activity that may have occurred within that organisation.

Who can be an eligible Whistle-blower?

  • An officer or employee (including volunteers)
  • An individual or an employee of a person that supplies services or goods to Hear and Say
  • An individual who is an associate of Hear and Say
  • A relative or dependent of any of the above, or a dependent of the spouse of any of the above
  • An individual prescribed by the Regulations as being an eligible Whistle-blower.
  • An eligible Whistle-blower can remain anonymous and still qualify for protection.

When does a Whistle-blower Qualify for Protection?

A Whistle-blower is entitled to protection under the Corporations Act if they make a qualifying disclosure to an eligible recipient.

A qualifying disclosure involves reporting conduct by Hear and Say or an officer or employee of Hear and Say that represents misconduct, an improper state of affairs or circumstances, or breach of the law. This can include conduct that:

  • contravenes the Corporations Act, or the ASIC Act
  • constitutes an offence against another Commonwealth law that is punishable by imprisonment for 12 months or more
  • represents a danger to the public or the financial system, or
  • is prescribed by the

To qualify for protection, the Whistle-blower must have reasonable grounds to suspect that the information they will disclose indicates misconduct. This does not include complaints, general feedback or workplace grievances.

To qualify for protection, a Whistle-blower must make their disclosure to an eligible recipient. An eligible recipient is:

  • An officer, Senior Manager or CEO of Hear and Say
  • The Board Chair of Hear and Say.
  • An auditor or member of the audit team for Hear and Say
  • 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.

Policy Statement: Our Commitment

Hear and Say is committed to supporting Whistle-blowers, promoting a culture that encourages and values their contributions, and providing the protections to Whistle-blowers set out in the Corporations Act 2001.

What are the Whistle-blower Protections?

Whistle-blower protections are the protections provided to Whistle-blowers to enable them to come forward to report misconduct without fear of retribution or personal detriment. This protection is provided by The Corporations Act 2001 (Cth) and the Taxation Administration Act 1953 (Cth).

Whistle-blowers, or potential Whistle-blowers, can be compensated for any loss, damage, or injury they suffer. It is illegal to fire, harass or discriminate against a Whistle-blower or potential Whistle-blower because someone thinks they made a disclosure.

Procedures

How does someone report Whistle-blower Information?

A person who believes there has been misconduct is responsible for reporting it and should contact the Hear and Say CEO in the first instance.

  • Scott Miller – phone: 3850 2111

A second point of contact that can be used is the Hear and Say Board Chair:

  • Verena Preston – phone: 3850 2111

How will Hear and Say Support and Protect Whistle-blowers?

A Whistle-blower Protection Officer will be appointed for each report received. This will be the Hear and Say CEO unless there are extenuating circumstances. The role of the Whistle-blower Protection Officer is to facilitate communications with the Whistle-blower and aid in protecting the Whistle-blowers’ anonymity.

Hear and Say will make all reasonable attempts to protect the anonymity of a Whistle-blower throughout the investigation process unless:

  • The Whistle-blower consents to their identity being disclosed,
  • The disclosure of the Whistle-blower’s identity is required by law,
  • Disclosure is necessary to prevent serious harm to a person’s health or safety,
  • Disclosure is necessary to enforce or protect Hear and Say’s legal rights or interests or to defend a claim.

How will Hear and Say Investigate Disclosures?

A Whistle-blower Investigation Officer will be appointed to oversee investigations stemming from Whistle-blower information. They will present the Board updates and findings in respect to investigations instigated.

How will Hear and Say treat those Subject to Investigation?

Anyone who is subject to an investigation will be treated with respect and given the opportunity to provide information towards the investigation.

How will we make the Policy Available?

The policy will be available internally with all other Hear and Say Policies and Procedures. The Policy will also be made available to those outside the organisation to access.

Last updated June 2026. Version 4.2.

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