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Whistleblowing Policy

Rationale and Scope

This policy is designed to encourage employees and other stakeholders to report suspected wrongdoing as soon as
possible, in the knowledge that their concerns will be taken seriously and investigated appropriately, and that their
confidentiality will be respected.

The Policy applies to APG and all of its Workforce Participants worldwide.

Policy Principles

Definition of Whistleblowing

Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include:

    • Criminal offenses (e.g., fraud, corruption, theft)
    • Failure to comply with legal obligations
    • Miscarriages of justice
    • Health and safety dangers
    • Environmental damage
    • Bribery
    • Any attempt to conceal any of the above

Raising a Concern

Concerns should be raised with:

    • Line Manager or Supervisor
    • HR Department
    • Your relevant contact at APG

If you prefer to report anonymously, you can do so by using the whistleblower email
(Whistleblowing@apgecommerce.com), or using our APG Whistleblower form

Alternatively, if you would like to report directly to the Australia Post Group, you can do so
via the Australia Post Group Our Ethics and Whistleblower Reporting Service portal.

Confidentiality and Anonymity

All disclosures will be handled with strict confidentiality to the extent legally permissible. The identity of the whistleblower will not be disclosed without their explicit consent, except as required by law or necessary for a proper investigation.

Protection from Retaliation

Whistleblowers will not suffer any detrimental treatment as a result of raising a concern in good faith. Retaliation against whistleblowers is prohibited and may lead to disciplinary action.

Investigation Process

Once a concern is raised:

    • It will be acknowledged within 1-3 days.
    • An initial assessment will be conducted.
    • If necessary, a formal investigation will follow.
    • The whistleblower may be kept informed as appropriate.

False Allegations

Deliberately false or malicious allegations may result in disciplinary action. However, no action will be taken against individuals who report in good faith, even if the concern is later found to be unsubstantiated.

Policy Support and Administration

This Policy is made available on the intranet and to subsidiaries and associated entities.
Training will be provided to all Workforce Participants about your rights and responsibilities, and you will be regularly
reminded about your responsibilities under this Policy.

The Policy will be reviewed at least every three years, or whenever there is a material change to the law or operating
environment to ensure it is up to date.

Policy Sponsor: Global HR, Legal & Compliance Director
Policy Owner: CEO
Approved By: Board
Effective Date: 30/09/2025
Next Review Date: 01/06/2026