Statement of Policy
Australia Post Group (Group) is committed to encouraging and supporting you to speak up if you have concerns about wrongdoing, and wish to report that suspected or actual wrongdoing.
The Group will properly consider any such disclosure of wrongdoing and take appropriate action, which may include an investigation. We will maintain your confidentiality as far as is possible and work with you to ensure you are protected from any detriment for making the disclosure of wrongdoing.
This Policy is supported by the Group Whistleblower Standard (Whistleblower Standard), which sets out the Group’s procedures in relation to receiving, handling, investigation and reporting of disclosures. These documents provide the framework for escalating disclosures of wrongdoing, to encourage, promote and facilitate ethical and accountable conduct in everything we do.
Rationale & Scope
This Policy covers disclosures that may reveal instances of serious wrongdoing or systemic misconduct (including conduct that is unlawful, corrupt or improper) as provided under the Public Interest Disclosure Act 2013 (Cth) or the Corporations Act 2001 (Cth). Recent enhancements to the Corporations Act 2001 (Cth) have increased the protections available to a person who wishes to raise a concern about serious wrongdoing or systemic misconduct.
This Policy does not apply to minor or personal work-related grievances and non-serious instances of suspected wrongdoing which do not relate to systemic issues of misconduct. These concerns are more appropriately managed under the relevant Group policy or procedure that applies to that conduct.
Audience & Application
This Policy applies to current and former employees of Australia Post and its subsidiaries, including StarTrack, Decipha, SecurePay and POLi Payments. It also applies to others with a connection to the Group, including board of directors, current and former contractors, suppliers, Licensed Post Office licensees and employees, consultants,
Group contracted service providers and their employees, public officials from other agencies, and any other whistleblower referred to in this Policy.
This Policy will be made publicly available in order to facilitate and encourage reports of wrongdoing.
The Group is committed to complying with the obligations relating to the protection of whistleblowers in the Public Interest Disclosure Act 2013 (Cth) and the Corporations Act 2001 (Cth).
In line with this Policy, the Group will
Enforcement & Monitoring
The Employee Relations team will have oversight of this Policy and ensure that disclosures are appropriately handled in line with the Group’s legislative obligations.
The Whistleblower Policy will be reviewed every three years or following any updates to governing legislation.
The Group is committed to working and acting in a way that is consistent with our Values of Trust, Inclusivity, Empowerment and Safety. We must also act with integrity and comply with applicable laws, regulations, codes, policies and procedures. We encourage our people to speak up when they see or suspect wrongdoing such as serious or systemic misconduct, unlawful or unethical behaviour, or conduct that may cause serious public harm. At the Group, we have the courage to open and honest, and take responsibility for our actions.
The Whistleblower Policy plays an important role in ensuring you feel safe and secure to raise concerns without fear of retaliation or victimisation. It provides information and guidance about who can be a whistleblower, how to report concerns, and the legal rights and protections that are available to whistleblowers.
When does the Whistleblower Policy apply?
This Policy applies if you want to report actual or suspected serious wrongdoing or systemic misconduct, unlawful or unethical behaviour, or conduct that may cause serious public harm. Making this kind of report is known as a Disclosure and will be handled as such under this Policy.
You should consider whether your concern can be more appropriately escalated or effectively addressed under another policy or process. If your concern relates to a personal work-related matter, inappropriate behaviour such as discrimination, harassment or bullying, or other non-serious and non-systemic issues of misconduct that do not have broader implications for the Group, you should report your concern under the relevant policy that applies, where it will be more appropriately managed:
If your concern relates to the following types of wrongdoing, and you have Reasonable Grounds to suspect the wrongdoing or misconduct, this Policy will support you to make a disclosure without fear of reprisal and with the protection of the Group:
a) Conduct or practices that may breach an Australian or foreign law, regulation or code (such as theft, drug sale or use, criminal damage);
b) Corrupt or fraudulent conduct (such as misappropriation of funds, bribery, undue influence, false or misleading information);
c) Maladministration or a substantial mismanagement or wastage of Australia Post’s resources (such as excess private use of a Group phone, unauthorised use of fuel cards for private vehicles, using Group resources/information for personal gain);
d) Conduct involving substantial risk to health or safety or significant danger to the environment or to the public;
e) Conduct involving potential breaches of human rights standards;
f) Conduct that may cause serious financial or non-financial loss to the Group or damage to its reputation and brand, or that may otherwise cause danger to the financial system; or
g) A serious breach of Our Ethics.
Do the whistleblower protections apply to me?
The whistleblower protections are available to:
a) Current and former Group employees and officers;
b) An individual contractor or supplier of goods or services (or their employee);
c) An individual associate of one of the Group’s subsidiaries; or
d) A spouse, relative or a dependent of any of the above.
|I am ...||Am I protected?|
|A current Group employee||√|
|A former Group employee||√|
|Working as an employee of a contractor providing goods or services to the Group||√|
|An individual in a business relationship with the Group or one of its subsidiaries||√|
|Related to, a spouse of or dependent on a current or former Group employee or individual contractor||√|
|A person who has not worked at the Group as an employee||X|
|A person who has not provided goods or services to the Group||X|
|A customer of the Group||X|
How do I make a disclosure?
If you believe that your concerns are best addressed under this Policy, you can make a disclosure using one of the following options:
If you are a supervisor or manager and you receive information from your employee that you think might meet the threshold conduct for a disclosure, you are required to report the information to the Whistleblower Hotline on 1800 799 353 or firstname.lastname@example.org
Can I make an anonymous disclosure?
You may choose to make a disclosure anonymously or using a different name. We encourage you to provide your identity/name when making a disclosure for practical reasons as anonymity can limit the investigation process.
Anonymous disclosures will be assessed in the same manner as any other disclosure and acted on to the extent practicable.
What information should I include in my disclosure?
You should provide as much detail as possible, to assist our whistleblower team to assess your disclosure and determine how to proceed, including:
What will happen to my disclosure?
Once you have made a disclosure, the Whistleblower team will document it and assess it to determine whether your disclosure falls within the scope of this Policy and requires further investigation.
If an investigation is required, the Group will notify you and provide an estimate of the timeframe for the investigation. It’s important that you use your best endeavours to assist with any investigation, regardless of whether or not you made the disclosure.
For more information regarding the Group’s processes and procedures relating to the allocation, investigation and notification of disclosures, refer to the Whistleblower Standard.
How am I protected?
If you make a disclosure, or you are involved in the investigation of a disclosure, the Group will:
The Group will not tolerate any form of actual or threatened detrimental conduct against you for making a disclosure, including:
Whistleblowers are also entitled to other immunities as a result of making a disclosure, including:
If you make a disclosure, the Group will take all reasonable steps to protect your identity. In some circumstances, it may be necessary for the Group to reveal your identity, for instance in order to effectively investigate a disclosure and ensure procedural fairness is afforded to all participants.. It may also be necessary for the Group to provide information to particular people (such as internal and external persons conducting the investigation, or to lawyers for the purpose of the Group seeking legal advice in relation to the issues raised in the disclosure). Your identity will only be disclosed if required and in accordance with the applicable legislation, and otherwise will be kept confidential in accordance with this Policy.
If you make a disclosure, you also have an obligation to maintain confidentiality. A failure to do so could have an adverse impact on the investigation and/or affect the rights of the other workplace participants involved in the matter.
How will false, malicious or non-genuine claims be handled?
A person who knowingly makes a false or misleading disclosure will not have any protections under the Public Interest Disclosure Act 2013 (Cth) or the Corporations Act 2001 (Cth).
If you make a disclosure and have reasonable grounds for believing the information disclosed indicates unlawful or improper conduct, but is found to be unsubstantiated following an investigation, no adverse action will be taken against you for making the disclosure.
However, if you make a disclosure that is malicious or deliberately upsetting, or about content that is knowingly false, you will be subject to investigation under the applicable disciplinary processes as required. Such investigation may result in disciplinary action up to and including termination of employment, or cessation of any contract for services.
Roles & Responsibilities
|The ARC/Board – reporting and on the implementation of governance frameworks||ARC/Board||The ARC/Board will ensure governance mechanisms and control frameworks are in place.|
|Accountable Executive||Executive General Manager, People & Culture||To oversee the application of the policy.|
|Compliance with regulatory obligations, policies and procedures. Undertake relevant training.||Workplace participants||Complying with obligations, policies and procedures, as well as behavioural guidelines.|
|Responsible for leading appropriate use of the Whistleblower Hotline||Managers||Facilitate awareness of how and when the Whistleblower Hotline should be used.|
Policy Monitoring & Oversight
|Administration||Employee Relations – Enterprise Services & Programs||Liaise regularly with external service provider of Whistleblower Hotline. Deliver reporting requirements to external bodies.|
|Compliance||Employee Relations – Enterprise Services & Programs||Oversee and ensure Group compliance to the principles of the Policy.|
|Breach & Incident Reporting||Employee Relations – Enterprise Services & Programs||Will undertake remediation and reporting for related matters to the Enterprise Risk Management Forum.|
|Periodic review and/or internal audit for compliance to this policy||Legal||Option to undertake periodic review and/or internal audit to ensure this policy is complied with and reporting of breaches and incidents to the EPF and ARC.|
|Authorised Officer||A person who is specifically identified as someone able to receive a Disclosure from a Whistleblower under the Public Interest Disclosure Act 2013 (Cth) or Corporations Act 2001 (Cth). This may include a member of the Board and other employees at senior levels of management within the Group. A list of our Group Authorised Officers is available on OurPost.|
|Group||Australia Post Group (Group). The Group is defined as the Australian Postal Corporation and its subsidiaries.|
|Disclosures||Includes “public interest disclosures” under the Public Interest Disclosure Act 2013 (Cth) and “disclosable matters” under the Corporations Act 2001 (Cth).|
|Reasonable Grounds||Means that a reasonable person in your position would also suspect the information indicates serious or systemic misconduct or a breach of the law.|
|Subsidiary||An Australia Post related body corporate.|
|Whistleblower||A person who makes an eligible public interest disclosure within the meaning of the Public Interest Disclosure Act 2013 (Cth) or a disclosure in accordance with the Corporations Act 2001 (Cth).|
|Workplace participant||An employee or contractor of the Group.|
Key Policy Information
|Administrative Area||Policy Information|
|Document Title||Whistleblower Policy|
Policy Owners and Governance Forums
|Administrative Area||Owner / Forum|
|Accountable Executive||Executive General Manager, People & Culture|
|Policy Owner||General Manager, Employee Relations|
|Policy Administrator||Head of Employee Relations, Enterprise Services & Programs|
|Policy Content Owner||General Manager, Employee Relations|
|Review and Approval Body||Audit & Risk Committee (Endorse) Board (Approve)|
|Policy Approval Date||21 August 2019|
|Policy Effective Date||21 August 2019|
|Next scheduled review||21 August 2022|