Whistleblower Policy

1. Purpose of the Policy

This Whistleblower Policy aims to:
  • Encourage the reporting of any instances of suspected unethical, illegal, fraudulent, or undesirable conduct involving Concentis.
  • Provide a transparent framework for the confidential reporting and investigation of such concerns.
  • Protect individuals who make disclosures from detrimental treatment and ensure they can report concerns without fear of reprisal.
  • Comply with legal obligations under the Corporations Act 2001 and the guidance from the Australian Securities and Investments Commission (ASIC).

2. Who the Policy Applies To

This policy applies to:
  • Employees (current and former)
  • Directors and officers
  • Contractors (including employees of contractors)
  • Suppliers (including employees of suppliers)
  • Associates
  • Consultants and volunteers
  • Relatives, dependents, spouses, or dependents of a spouse of any of the above individuals.

3. What is an Eligible Disclosure?

Eligible Disclosures qualifying for protection under this policy include:
  • Conduct that is illegal, unethical, or contrary to Concentis policies.
  • Conduct that is oppressive, discriminatory, grossly negligent, or constitutes gross mismanagement.
  • Conduct that involves a substantial risk to public health or safety, or to the stability of, or confidence in, the financial system.
Ineligible Disclosures Include:
Personal work-related grievances such as interpersonal conflicts, decisions about promotions or transfers, or disciplinary actions.

4. Who Can Receive an Eligible Disclosure

Eligible Disclosures can be made to:
  • The Directors of Concentis
  • Legal practitioners for obtaining legal advice or legal representation about the whistleblower protections.
  • Regulatory bodies such as ASIC, APRA, or the ATO.
  • Journalists or parliamentarians under specific public interest or emergency disclosure conditions.

5. How to Make an Eligible Disclosure

Eligible Disclosures can be made through:
  • Email to whistleblower@concentis.com.au
  • Secure and confidential online form accessible outside business hours found below
  • Direct contact with eligible recipients within Concentis.

6. Legal Protections for Eligible Disclosers

Eligible Disclosers qualifying for protection are protected under the Corporations Act, which includes:
  • Identity protection (confidentiality).
  • Protection from detrimental acts or omissions.
  • Compensation and remedies.
  • Protection from civil, criminal, and administrative liability.

7. Support and Practical Protection for Eligible Disclosers

Concentis will:
  • Keep the identity of the Eligible Discloser confidential unless legally required to disclose it.
  • Protect Eligible Disclosers from detrimental acts or omissions.
  • Provide support services such as counselling or legal advice to Eligible Disclosers.

8. Handling and Investigating an Eligible Disclosure

Upon receiving a disclosure, Concentis will:
  • Assess if the disclosure qualifies for protection and if a formal investigation is required.
  • Conduct investigations while maintaining confidentiality and appropriate documentation.
  • Keep the discloser informed about the investigation’s progress and outcome, ensuring confidentiality and security.

9. Fair Treatment of Eligible Disclosures

Concentis ensures that:
  • Employees mentioned in disclosures are treated fairly and impartially.
  • Investigations focus on the substance rather than the motive of disclosures.

10. Ensuring the Policy is Easily Accessible

Concentis will:
  • Make this policy available on the Concentis website and internal platforms.
  • Provide regular training and updates to ensure all relevant parties are aware of any changes to the whistleblower policy.

11. Review and Updates

Concentis commits to regularly reviewing and updating this policy to ensure its effectiveness and compliance with current laws and regulations.
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