Whistleblower Policy
1. Background
1.1 The Board of Benevolence and of Aged Masons, Widows and Orphans’ Fund (BOB) is the committed to operating:
(1) legally, in accordance with all laws and legislation;
(2) properly, in accordance with all organisational policy and procedures; and
(3) ethically, in accordance with recognised ethical principles and the fundamental values of the Freemasons.
1.2 As such, employees and people that work within the BOB are expected and encouraged to cooperate with the BOB in maintaining legal, proper and ethical activities and operations, including, if necessary, reporting non-compliant conduct by other people.
2. Purpose
2.1 This policy:
(1) is designed to give guidance so that honesty and integrity are maintained at all times at BOB; and
(2) deals with issues relating to those employees (or others) who wish to raise issues about whether BOB or its employees have complied with applicable laws and other standards of behaviour (such as BOB’s policies or codes of conduct).
1.2 The purpose of this policy is to:
(1) encourage the reporting of matters that may cause harm to individuals or financial or non-financial loss to BOB or damage to its reputation;
(2) enable BOB to deal with reports from whistleblowers in a way that will protect the identity of the whistleblower and provide for the secure storage of the information provided;
(3) establish the mechanisms for protecting whistleblowers against victimisation by any person, whether internal or external to BOB;
(4) provide for the appropriate internal infrastructure to achieve the above; and
(5) help to ensure BOB maintains the highest standard of ethical behaviour, integrity and legal compliance.
3. Policy
3.1 Policy application
This policy applies to all directors, employees and others working within BOB.
BOB expects its employees who reasonably suspect potential cases of Reportable Conduct or become aware of actual Reportable Conduct to make a report under this policy or under any other applicable policies.
3.2 Reportable conduct
You may make a report pursuant to this policy if you genuinely, and have reasonable grounds to suspect that a BOB director, officer, employee, contractor, supplier, tenderer or other person who has dealings with BOB has engaged in conduct which:
(1) is dishonest, fraudulent or corrupt;
(2) is illegal (such as theft, violence, harassment or intimidation, or constitutes a breach of state or federal law);
(3) is unethical or in breach of BOB’s policies (such as wilfully breaching a code of conduct, dishonestly altering company records etc);
(4) is potentially damaging to BOB, a BOB employee, or a third party, such as unsafe work practices;
(5) may cause financial loss to BOB or damage its reputation or otherwise be detrimental to BOB’s interests;
(6) involves harassment, discrimination, victimisation or bullying, other than a Personal Work Grievance; or
(7) involves any other kind of misconduct or an improper state of affairs or circumstances.
This is known as Reportable Conduct.
3.3 Who you can report to
Reports should be made to any of the following Compliance Officer:
Alasdair Begley – Board Chairman whistleblower1@handheartpocket.org.au
Jane Crombie – Chair Finance Risk Audit Committee whistleblower2@handheartpocket.org.au
Rob Qualtrough – Company Secretary 07 3493 6005 or BoardSec@handheartpocket.org.au
3.4 Investigations of Reportable Conduct
(1) BOB will investigate all matters reported pursuant to this policy as soon as practicable once a report has been received.
(2) A Compliance Officer may, with your consent, appoint someone to assist in any investigation. Where appropriate, BOB may, in its discretion, provide you with feedback regarding the investigation’s progress and/or outcome.
(3) An investigation will be conducted in a fair and objective manner, as is reasonable and appropriate having regard to the nature of the Reportable Conduct, the report made and any relevant circumstances.
(4) The particular enquiries made and the process of any investigation will be determined by the nature and substance of the report. This may include the investigation being undertaken internally or the appointment of an independent third party.
(5) If a report is not made anonymously, a Compliance Officer will, as soon as practicable, be in contact with you to discuss the investigation process including who may be contacted during the process and other matters relevant to the investigation.
(6) If a report is made anonymously, BOB will conduct the investigation and its enquiries based solely on the content of the report.
3.5 Protection of whistleblowers
To encourage reporting, BOB is committed to ensuring the confidentiality of all matters raised under this policy and the protection and fair treatment of those who make a report.
(1) Protection against detrimental treatment
(a) Detrimental treatment includes dismissal, demotion, harassment, discrimination, bullying, disciplinary action, threats, bias or other unfavourable treatment connected with making a report under this policy.
(b) If you are subjected to detrimental treatment as a result of making a report under this policy, you should immediately inform a Compliance Officer.
(2) Protection of your identity and confidentiality
(a) Subject to any legal requirements, on receiving a report under this policy, BOB will only share your identity as a whistleblower or information likely to identify you if:
(i) you consent;
(ii) the report is made to ASIC, the Australian Taxation Office or the AFP; or
(iii) the concern is raised with a lawyer for the purpose of obtaining legal advice or representation.
(b) Any disclosures of your identity or information likely to reveal your identity will be made on a strictly confidential basis.
(3) Protection of files and records
(a) BOB will ensure that all files and records created from an investigation arising from a report made under this policy will be stored securely.
3.6 Dictionary
(1) In this policy:
(a) ASIC means the Australian Securities and Investments Commission;
(b) Corporations Act means the Corporations Act 2001 (Cth);
(c) Officer has the same meaning as defined in the Corporations Act and includes a director or secretary of BOB;
(d) Personal Work Grievance has the same meaning as personal work-related grievance as defined in the Corporations Act and means information disclosed relating to the discloser if:
(i) the information concerns a grievance about any matter in relation to the discloser’s employment, or former employment, having (or tending to have) implications for the discloser personally; and
(ii) the information:
(A) does not have significant implications for BoB; and
(B) does not concern Reportable Conduct;
(e) Reportable Conduct has the meaning given in clause 3.2.
This policy is reviewed annually as part of the regular governance processes of the organisation.
Last review August 2024.
