UAC whistleblower policy

Policy for whistleblower rights and protections

Purpose

UAC is committed to the highest ethical and professional standards of conduct and performance in all its business activities and to promoting and supporting a culture of ethical behaviour and good corporate governance.

UAC encourages the reporting of any matters of unethical, illegal, fraudulent or undesirable conduct that will harm the reputation, values and ethics of the company so that appropriate action can be undertaken.

Whistleblowing is the disclosure of information by a person (the whistleblower) who makes a report to UAC in connection with concerns regarding unethical, illegal, fraudulent or undesirable conduct of the company or a person who carries out work for the company.

UAC is required to implement a whistleblower policy to comply with the whistleblower protections law in section 1317AI of the Corporations Act 2001. The policy defines UAC’s internal whistleblowing mechanism for reporting, investigating and administrating wrongdoing within the workplace and to strengthen the protections available to whistleblowers.

A person who makes a disclosure of false information is not afforded any protection under this policy and may be subject to disciplinary action.

UAC will make this policy available on the company website, intranet and in such other ways as will ensure the policy is available to employees, members of the UAC Board and persons wishing to use it.  

Objectives

The objectives of the policy are to provide whistleblowers a clear understanding of:                  

  • who can make a qualifying disclosure (eligible whistleblowers)
  • the scope of disclosures that qualifies for protection (qualifying disclosure)
  • the category of person to whom a qualifying disclosure may be made (eligible recipients)
  • protections available to whistleblowers
  • how UAC will ensure fair treatment of persons who are mentioned in disclosures that qualify for protection or to whom such disclosures relate 
  • how UAC will investigate disclosures that qualify for protection.                                      

Scope

This policy applies to everyone who carries out work for UAC. This policy does not apply to work-related grievances in relation to the whistleblower’s employment.

Eligible whistleblowers

Eligible whistleblowers include current and former employees, board members, suppliers of goods and services (including their employees) or their relatives and dependants.

Qualifying disclosure

Disclosures qualifying for protection must be made by an eligible whistleblower and the disclosure is made to an eligible recipient.

Disclosable matters include information indicating that UAC or an employee or agency staff of UAC or a board member has engaged in misconduct or an improper state of affairs or circumstances.

Eligible recipients

You can make a report to any one of the persons listed below:

  • UAC Board Chair
    Professor Andrew Parfitt
    Email: andrew.parfitt@uts.edu.au                                         
  • Managing Director
    Dr David Christie
    Email: david.christie@uac.edu.au                                          
  • General Manager, People and Finance
    Mr Tim Gleeson   
    Email: tim.gleeson@uac.edu.au  
  • Human Resources Manager
    Ms Jennie Edwards
    Email: jennie.edwards@uac.edu.au

Reports may also be posted to UAC, Locked Bag 112, Silverwater, NSW 2128 (marked to the attention of one of the persons above) or emailed to the Company Secretary, Mr Michael Berg: michael.berg@uac.edu.au.

Protection of whistleblowers

UAC 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. Where the investigation has found that the person making the allegation made it in good faith on reasonable grounds, UAC will ensure that the person suffers no detrimental treatment and will provide additional support to the person where necessary.

Protection of identity and confidentiality

UAC is committed to preserving the confidentiality of:

  • the information or the identity of the whistleblower unless the whistleblower has consented to the disclosure
  • the identity of the person who is the subject of disclosure
  • the fact of the disclosure.

UAC will make all reasonable efforts to ensure the identity of the parties remains confidential throughout the investigation process. UAC will not disclose their identity unless a court or tribunal thinks it necessary or in the interests of justice.

Protection against detrimental treatment

Detrimental treatment includes dismissal, demotion, personal injury, harassment, intimidation, discrimination, damage to a person’s business or financial position, damage to a person’s reputation 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 the eligible recipients in this policy immediately.

Protection of files and records   

All records created from an investigation will be retained securely. Unauthorised release of information is in breach of this policy and will be subject to disciplinary action.

Investigation

An investigation team is formed to determine whether sufficient information exists to allow the report to be investigated, whether an investigation is required and, if so, determine the necessary action to investigate the disclosure. UAC will ensure that the team members will not present a real or apparent conflict of interest with the investigation outcome.

Strict security will be maintained during the investigation process. All information obtained will be properly secured to prevent unauthorised access.

UAC will apply principles of procedural fairness and natural justice to the conduct of any investigation and resultant findings so that the investigation is conducted on a fair and impartial basis. The matters which are the subject of the investigation are made known to the person who is the subject of the disclosure and that person is given adequate opportunity to respond to those matters.

A whistleblower will be informed of the progress and outcome of an investigation when deemed appropriate by UAC.

Victimisation

UAC is committed to ensuring that the whistleblower is not victimised. UAC will thoroughly investigate reports of victimisation. If proven, those who have victimised may be subject to disciplinary action or dismissal.