Whistleblower Protection Policy

Whistleblower Policy

1. Purpose

Gredstrond Limited is committed to the highest standards of conduct and ethical behaviour in all of our business activities and to promoting and supporting a culture of honest and ethical behaviour, corporate compliance and good corporate governance.

This Policy is intended to encourage the reporting of any instances of suspected unethical, illegal, fraudulent or undesirable conduct involving Gredstrond Limited and provides protections and measures so that those persons who make a report may do so confidentially and without fear of intimidation, disadvantage or reprisal.

You may make a report under this Policy if you have reasonable grounds to suspect that a director, officer, manager, team member, contractor, supplier, tenderer or other person who has business dealings with Gredstrond Limited has engaged in Reportable Conduct, as defined below.

2. Application

This Policy applies to all team members and officers of Gredstrond Limited and other eligible whistleblowers including suppliers and contractors. This Policy also has application to the additional persons who are eligible whistleblowers who have special protections under the Corporations Act and Tax Act as set out in Schedule A and Schedule B of this Policy.

3. What is reportable conduct?

You may make a report under this policy if you have reasonable grounds to suspect that Whistleblower Protection Policy director, officer, employee, contractor, supplier, tenderer or other person who has business dealings with Whistleblower Protection Policy has engaged in conduct ("Reportable Conduct") which:

a) is dishonest, fraudulent or corrupt, including bribery or other activity in breach of the Gredstrond Limited in Policy Anti-Bribery Policy;

b) is illegal activity (such as theft, violence, harassment or intimidation, criminal damage to property or other breaches of state or federal law);

c) is unethical or in breach of Gredstrond Limited policies (such as dishonestly altering company records or data, adopting questionable accounting practices or wilfully breaching Gredstrond Limited’s Code of Conduct or other policies or procedures);

d) is potentially damaging to Gredstrond Limited, a Gredstrond Limited employee or a third party, such as unsafe work practices, environmental damage, health risks or abuse of Gredstrond Limited's property or resources;

e) amounts to an abuse of authority;

f) may cause financial loss to Gredstrond Limited or damage its reputation or be otherwise detrimental to Gredstrond Limited’s interests;

g) involves harassment, discrimination, victimisation or bullying, other than personal work-related grievances as defined in the Corporations Act 2001 (Cth) ("Corporations Act"); or

h) involves any other kind of misconduct or an improper state of affairs or circumstances.

Annexure A describes special protections for whistleblowers who disclose information concerning misconduct or an improper state of affairs or circumstances in relation to Gredstrond Limited or a related body corporate under the Corporations Act.

4. Who can make a report to?

For the purposes of this policy to ensure appropriate escalation and timely investigation, we request that reports are made to us.

5. GREDSTROND LIMITED investigation of reportable conduct 

Gredstrond Limited will investigate all matters reported under this policy as soon as practicable after the matter has been reported. A Protected Disclosure Officer may, with your consent, appoint a person to assist in the investigation of a report. Where appropriate, Gredstrond Limited will provide feedback to you regarding the investigation’s progress and/or outcome(subject to considerations of the privacy of those against whom allegations are made).

The investigation will be conducted in an objective and fair manner, and otherwise as is reasonable and appropriate having regard to the nature of the Reportable Conduct and the circumstances. While the particular investigation process and enquiries adopted will be determined by the nature and substance of the report, in general, as soon as practicable upon receipt of the report, if the report is not anonymous, a Protected Disclosure Officer or investigator will contact you to discuss the investigation process including who may be contacted and such other matters as are relevant to the investigation.

Where a report is submitted anonymously, Gredstrond Limited will conduct the investigation and its enquiries based on the information provided to it.

6. Protection of whistleblowers

Gredstrond Limited is committed to ensuring confidentiality in respect of all matters raised under this policy, and that those who make a report are treated fairly and do not suffer detriment.

a. Protection against detrimental conduct

Detrimental treatment includes dismissal, demotion, harassment, discrimination,

disciplinary action, bias, threats or other unfavourable treatment connected with

making a report. If you are subjected to detrimental treatment as a result of making a report under this policy you should:

• Inform a protected disclosure officer, officer or senior manager within your

relevant division/business unit immediately under the divisional

whistleblower policy; or

• raise it in accordance with paragraph 3 of this policy.

b. Protection of your identity and confidentiality

Subject to compliance with legal requirements, upon receiving a report under this

policy, Gredstrond Limited will only share your identity as a whistleblower or information

likely to reveal your identity if:

• you consent;

• the concern is raised with a lawyer for the purpose of obtaining legal

advice or representation.

If Gredstrond Limited needs to investigate a report, it may disclose information that

could lead to your identification, but it will take reasonable steps to reduce this


Any disclosures of your identity or information likely to reveal your identity will be

made on a strictly confidential basis.

c. Protection of files and records

All files and records created from an investigation will be retained securely.

Unauthorised release of information to someone not involved in the investigation

(other than senior managers or directors who need to know to take appropriate action,

or for corporate governance purposes) without your consent asa whistleblower will be

a breach of this policy.

Whistleblowers are assured that a release of information in breach of this policy will

be regarded as a serious matter and will be dealt with under Gredstrond Limited's

disciplinary procedures.

7. Duties of employees in relation to reportable conduct

It is expected that employees of Gredstrond Limited who become aware of actual or suspect on reasonable grounds, potential cases of Reportable Conduct will make a report under this policy or under other applicable policies.

8. Group reporting procedures

Gredstrond Limited and Protected Disclosure Officers (as appropriate) will report to the Gredstrond Limited Board on whistleblower incident reports. These reports will be made on a ‘no names’ basis and will not include information that could lead to the identity of a whistleblower, maintaining the confidentiality of matters raised under this Policy. In general, these reports will:

  • provide a summary of Reportable Conduct incident reports made that relate to Gredstrond Limited on a no names basis, their status and action being taken; 

  • identify any patterns of conduct, including for example, patterns within or across the

division; and

  • make recommendations, as appropriate, including in relation to allocation of resources

or areas requiring further attention.

9. Amendment of this policy

This policy cannot be amended without approval of the Managing Director of the Gredstrond Limited. It will be reviewed from time to time to ensure that it remains effective and meets best practice standards and the needs of Gredstrond Limited.

Annexure A – Special protections under the Corporations Act

The Corporations Act gives special protection to disclosures about any misconduct or improper state of affairs relating to Gredstrond Limited if the following conditions are satisfied:

1. the whistleblower is or has been:

a. an officer or employee of a Gredstrond Limited company;

b. an individual who supplies goods or services to a Gredstrond Limited company or an employee of a person who supplies goods or services to a Gredstrond Limited company;

c. an individual who is an associate of a Gredstrond Limited company; or

d. a relative, dependent or dependent of the spouse of any individual referred to

at (a) to (c) above;

2. the report is made to:

a. a Protected Disclosure Officer;

b. an officer or senior manager of a Gredstrond Limited company concerned;

c. Gredstrond Limited' external auditor (or a member of that audit team);

d. an actuary of a Gredstrond Limited company;

e. ASIC;

f. APRA; 

3. the whistleblower has reasonable grounds to suspect that the information being

disclosed concerns misconduct, or an improper state of affairs or circumstances in

relation to the Gredstrond Limited. This may include a breach of legislation including the

Corporations Act, an offence against the Commonwealth punishable by imprisonment

for 12 months or more, or conduct that represents a danger to the public or financial


Examples of conduct which may amount to a breach of the Corporations Act include:

insider trading, insolvent trading, breach of the continuous disclosure rules, failure to

keep accurate financial records, falsification of accounts, failure of a director or other

officer of the Gredstrond Limited to act with the care and diligence that a reasonable person would exercise, or to act in good faith in the best interests of the corporation or failure of a director to give notice of any material personal interest in a matter relating to the affairs of the company.

The protections given by the Corporations Act when these conditions are met are:

1. the whistleblower is immune from any civil, criminal or administrative legal action

(including disciplinary action) for making the disclosure;

2. no contractual or other remedies may be enforced, and no contractual or other right

may be exercised, against the whistleblower for making the report;

3. in some circumstances, the reported information is not admissible against the

whistleblower in criminal proceedings or in proceedings for the imposition of a


4. anyone who causes or threatens to cause detriment to a whistleblower or another

person in the belief or suspicion that a report has been made, or may have been 

made, proposes to or could be made, may be guilty of an offence and may be liable

for damages;

5. a whistleblower's identity cannot be disclosed to a Court or tribunal except where

considered necessary; and

6. the person receiving the report commits an offence if they disclose the substance of

the report or the whistleblower’s identity, without the whistleblower’s consent, to

anyone except ASIC, APRA, the AFP or a lawyer for the purpose of obtaining legal

advice or representation in relation to the report.


If a report is made, the identity of the discloser must be kept confidential unless one of the

following exceptions applies:

a. the discloser consents to the disclosure of their identity;

b. disclosure of details that might reveal the discloser's identity is reasonably necessary

for the effective investigation of the matter;

c. the concern is reported to ASIC, APRA, or the AFP; or

d. the concern is raised with a lawyer for the purpose of obtaining legal advice or


Guidelines for managing whistleblower reports

The Gredstrond Limited Policy sets out a summary of Gredstrond Limited’s commitment to the

protection of whistleblowers. This Policy applies to support and protect persons who become aware of, or suspect cases of Reportable Conduct.

1. A Protected Disclosure Officer or senior manager who receives a whistleblower report should:

a. Provide the whistleblower with a copy of this Policy and a copy of the

Acknowledgment and Consent to Disclosure for Investigation and Reporting

Purposes ("Consent") (on the next page of this Policy).

b. If the whistleblower signs the Consent, refer the matter to one of the

Authorised Persons referred to in the Consent for the matter to be


c. If the whistleblower is unwilling to sign the consent or the report is anonymous, you may disclose the substance of the report to an appointed investigator, provided that any identifying information about the whistleblower is removed or redacted, so that the report as referred to does not disclose the identity of the whistleblower or information that is likely to lead to the identification of the whistleblower (except where reasonably necessary for the purposes of investigating the matter and provided that all reasonable steps have been taken to reduce the risk that the whistleblower will be identified).

2. Attached is a form of consent (Appendix A) to enable reports to be disclosed to an

Authorised Person for proper investigation.

3. Whistleblower laws protect a whistleblowers’ confidentiality and against detrimental

conduct towards them for making a report. It is therefore critical that such reports are

treated with the utmost confidentiality and addressed according to this guideline.

4. Severe penalties may apply where a whistleblower's identity is revealed in breach of whistleblower laws or they are subjected to detrimental conduct, including in relation to their employment, as a result of making a report under this Policy.

Acknowledgement and Consent to Disclosure for Investigation

and Reporting Purposes


1. I have made a disclosure of information to the following person:

………………………………………     ………………………………………

                 Name                                                     Title

2. I have reasonable grounds to suspect that the information concerns Reportable Conduct.

3. I have received a copy of the Gredstrond Limited Whistleblower Policy. I understand that

information about my report that is unlikely to reveal my identity can be disclosed without

my consent.

4. I understand that if my report is captured under whistleblower protections set out in

whistleblower laws, my identity and information that is likely to lead to my identity cannot be

disclosed unless authorized by law in the following circumstances:

a. my consent has been given; or

b. is disclosed to a legal practitioner for the purpose of obtaining advice and

representation in relation to whistleblower laws; or

c. is reasonably necessary for the purpose of investigation of the matter and all

reasonable steps to reduce the risk that I will be identified have been taken; 

5. I hereby give my consent to the disclosure of this information, under conditions of

confidentiality, and for the purpose of investigation and reporting as set out in this Policy to

the following persons:

………………………………………           ………………………………………

                    Name                                                          Name

………………………………………            ………………………………………

                    Name                                                          Name


………………………………………           ………………………………………

Name of reporting person (print)                              Signature