Whistleblower Policy

Once you have made your report, it will be de-identified and passed to a Whistleblower Protection Officer (WPO). You may nominate a particular WPO should you so wish.

The WPO will assess your report to determine:

• If it falls within the Whistleblower Policy and you are eligible for protection or if the matter is more appropriately dealt with by another policy or procedure.
• If an investigation is required and who will investigate it.
• Any risks to you or your identity being revealed and how to mitigate the risks to ensure you are protected.

If an investigation is required, it will be undertaken by the Whistleblowing Investigations Officer (WIO) or an external party.

The Internal Audit Lead and the Head of People Services or their respective delegates are appointed by St John WA as Whistleblower Investigations Officers.

The WIO or external investigator will update the Whistleblower Protection Officer (WPO).

The WPO has responsibility for protection and safeguarding your interests as a ‘Discloser’ and, if you are not anonymous, is responsible for keeping you updated.

Anonymised, high level and trend reporting will be provided to the St John WA Board Health, Safety & Culture Committee.

You can make an anonymous report or ask for your identity to be protected. If you make an anonymous report, then we will not be able to provide feedback to you and will conduct any investigation on the information provided.

Subject to compliance with legal requirements, when we receive your report, we will take reasonable steps to keep your identity confidential and reduce the risk of disclosure during an investigation. We will only share your identity as a whistleblower or information likely to reveal your identity if:

• you consent
• the concern is reported to the Australian Securities and Investment Commission, the Australian Prudential Regulation Authority, the Tax Commissioner, or the Australian Federal Police
• the concern is raised with a lawyer for the purpose of obtaining legal advice or representation.

Any disclosures of your identity or personal information likely to reveal your identity will be made on a strictly confidential basis.

It is a criminal offence, as well as a breach of the Whistleblower Policy, for a person to disclose your identity as a whistleblower, or any information that may lead to your identification as a whistleblower, other than in accordance with the Policy.

If you have concerns about this, please speak to Stopline or our Whistleblower Protection Officers before making a report.

Please see the full Policy for more details.

If an allegation is made against you, we will support and treat you fairly by:

• Ensuring a fair and independent assessment of the allegation
• Keeping the details of the report and any allegations contained within it confidential and disclosed only to those who need to know
• Ensuring a fair and independent investigation process in accordance with Procedural Fairness (Procedural fairness relates to the fairness of the procedure in which a concern investigated is ultimately substantiated or unsubstantiated, and not the fairness in a substantive sense of the decision)
• As far as we are permitted under law, if there is evidence of wrongdoing by you, this evidence will be put to you prior to us deciding whether to take disciplinary action against you

We recognise that this situation may be stressful and remind you that all team members have access to the St John WA Employee Assistance Program. Please talk to your Whistleblower Protection Officer (WPO) about the support options available to you.

You can appeal to a WPO if you wish to raise a concern about the procedural fairness of an investigation.

You may make a report under the Whistleblower Policy if you have reasonable grounds to suspect that one of Our People or a Supplier has engaged a Disclosable Matter.

A ‘Disclosable Matter’ arises where you have reasonable grounds to suspect that one of our Team Members has engaged in conduct which:

• concerns Misconduct (as defined in the Policy) or an improper state of affairs in relation to St John WA (this concerns conduct which goes to the organisation as a whole, its governance, or its integrity), e.g.:
  • bribery, kickbacks, fraud, corruption, or improper use of authority; or
  • dishonestly altering company records or data, adopting questionable accounting practices, or inappropriately accessing patient records;
• is an offence under the Corporations Act, the ASIC Act, or other Commonwealth law;
• amounts to an abuse of authority or a Conflict of Interest;
• represents a significant danger or risk to public safety, or the stability of or confidence in the financial system;
• involves any other kind of Misconduct or an improper state of affairs or circumstances in relation to St John WA, including retaliatory action against anyone raising a concern under the Whistleblower Policy.

Disclosures that are not a Disclosable Matter do not qualify for protection under the Corporations Act.

Disclosable matters generally do not include personal work-related grievances, such as those which only have implications for the team member and not broader issues for St John WA.

You do not have to have proof of your concerns, but you must be honest and have reasonable grounds to suspect something is wrong. It does not matter if a concern turns out to be unsubstantiated (not proven by evidence) if the disclosure has been honestly made.

It is a serious breach of this Policy to knowingly raise false information or allegations. Any instances of this will lead to disciplinary action, including dismissal.

Please see the full Policy for more details.

If an investigation is required, the Whistleblower Protection Officer (WPO) will discuss any investigation with you (unless your report is anonymous).

All investigations must be conducted by someone who is independent from the business unit and team member concerned. In most cases, this will be by a Whistleblower Investigations Officer.

If you are not satisfied with the outcome of the investigation, you can lodge a complaint with the relevant regulator such as ASIC, APRA or the ATO.

If we approve a review, the review will be conducted by someone who was not involved in the original report handling and investigation.

We are committed to ensuring you have a safe and supportive environment when making a report. We will take all reasonable steps to protect your wellbeing, including assessing any risks to you and developing an appropriate support plan with you. Team members can also access the St John WA Employee Assistance Program.

We will not tolerate any detrimental action taken against anyone who makes a report under the Whistleblower Policy. Detrimental action may include:

• Termination of employment
• Changes to your role or duties that disadvantage you
• Unfair treatment or discrimination compared to other team members
• Harassment or intimidation
• Physical or psychological harm
• Damage to your property, reputation, business, or financial position
• Any other unfavourable treatment connected with making a report

Reporting under the Whistleblower Policy does not provide immunity from disciplinary, regulatory, or criminal action if wrongdoing has occurred.

Please see the full Policy for more details on what is and is not considered detrimental action.