Whistle Blower Policy

1. Purpose

At Arcadia Group we are guided by our company values. These values are the foundation of how we conduct ourselves and interact with each other, our clients, members, suppliers, shareholders and other stakeholders. The Company is committed to ensuring corporate compliance and promoting ethical corporate culture by observing the highest standards of fair dealing, honesty and integrity in our business activities.

The policy has been established to ensure any concerns raised regarding any misconduct or improper state of affairs or circumstances in relation to the Company’s business are dealt with effectively, securely, appropriately, and in accordance with the Corporations Act 2001 (Cth) (the Act).

The Board and Arcadia Group encourages the reporting of any instances of suspected unethical, illegal, corrupt, fraudulent or undesirable conduct involving the Company’s business and provides protections and measures to individuals who make a disclosure in relation to such conduct without fear of victimisation or reprisal.

This policy will be provided to all employees and officers of the Company upon commencement of their employment or engagement.

This Policy provides a transparent and confidential process for reporting suspected wrongdoing as quickly as possible, ensuring that concerns will be taken seriously and investigated appropriately, and that those who raise genuine concerns can do so without fear of reprisals.

2. Scope

The Board and Arcadia Group are responsible for creating a working culture that encourages all Arcadia Group employees to raise genuine concerns. The Policy applies to all employees of Arcadia Group and its subsidiaries, regardless of whether they work full-time, part-time, as casuals, or are engaged as Consultants, Contractors, Subcontractors, or volunteers.

Arcadia Group is required to ensure that the above are made aware of the existence and content of the Policy and their responsibility to report any wrongful conduct in the execution of their duties.

3. Responsibility for the Policy

Board

The Board is responsible for adopting the Whistle-Blower Policy and Procedure, and for nominating the organisation’s Whistle-Blower Protection Officer.

Chief Executive Officer

The Chief Executive Officer (“CEO”) is responsible for the implementation of the Whistle-Blower Policy and Procedure.

Whistle-Blower Protection Officer

The Whistle-Blower Protection Officer (“WPO”) will safeguard the interests of the Discloser making reports under this Procedure and will ensure the integrity of the reporting mechanism. The WPO will refer any reports that require further investigation to the relevant authorities.

The WPO reports directly to the CEO or Company Secretary. The WPO also has access to independent advisers as and when required. The current WPO is the HR/Payroll Advisor.

Employees, Volunteers, Contractors, Consultants etc

Are responsible for reporting breaches of general law, organisational policy, or generally recognised principles of ethics to a person authorised to act on such breaches.

4. Policy

This policy will be monitored and reviewed for its effectiveness every two years.

Reportable Conduct

Reportable Conduct not only covers possible improprieties in matters of financial reporting but also:

fraudulent or illegal activity;
corruption, bribery or blackmail;
criminal offences;
conflicts of interest;
unethical or otherwise conduct that has the potential to damage Company’s reputation;
Potentially damaging to the Company, its employees or a third party;
failure to comply with legal or regulatory obligation;
endangering the health and safety of an individual; and
concealment of any of the above.

Any disclosures that do not fall within the definition of Reportable Conduct, will not qualify for protection under the Act.

Disclosure of Reportable conduct

The Company expects employees to maintain a culture of honest and ethical behaviour. Accordingly, if you become aware of any Reportable Conduct, it is expected that you will make a disclosure under this policy.

If any employee believes reasonably and in good faith that malpractice exists in the workplace, they should report this immediately to their own line manager. However, if for any reason they are reluctant to do so, they should report their concerns to either:

Chief Executive Officer;
Group Company Secretary; or
Whistle-Blower Protection Officer (“WPO”).

Refer Whistle Blower Procedure (COR_0003_PR-1.10).

Any employee who makes a disclosure under this policy or is implicated as a result of a disclosure that is made may access the Company’s Employee Assistance Program (EAP) which is a free and confidential counselling service.

Anonymity

When making a disclosure, you may do so anonymously. It may be difficult for the Company to properly investigate the matters disclosed if a report is submitted anonymously and therefore the Company encourages you to share your identity when making a disclosure, however you are not required to do so.

Where a disclosure has been made externally and you provide your contact details, those contact details will only be provided to a WPO with your consent.

Protection and support

It is understandable that whistle-blowers are sometimes concerned about possible repercussions emanating from the complaints or concerns lodged. Arcadia Group aims to encourage openness and will support employees and others who raise genuine concerns under this policy and all concerns will be treated fairly and properly. Any whistle blower making a disclosure will retain their anonymity unless they agree otherwise.

No individual raising genuinely held concerns in good faith under this policy will be dismissed or be subject to any detrimental consequences arising from their actions such as unwarranted disciplinary action, victimisation, threats, or other unfavourable treatment.

The Board and Arcadia Group will not tolerate the harassment or victimisation of anyone raising a genuine concern. If any employee is found guilty of such conduct, that employee will be subject to disciplinary action. Arcadia Group will ensure the Whistle Blower is aware of who is handling the matter. If any employee is subjected to detriment as a result of making a disclosure, they should raise it as per the reporting procedure.

Support will be offered to whistle-blowers as appropriate, regardless of whether a formal response is carried out (e.g., an investigation). This may include employee assisted services and any other appropriate support as needed.

If any Arcadia Group employee is found to have made an allegation that they knew to be false, they will be subject to disciplinary action, up to and including termination of employment.

5. Confidentiality

All information received from you will be treated confidentially and sensitively. Whistle-blowers who have raised concerns internally will be informed who is handling the matter, how they can contact them, and if there is any further assistance required. The Company will provide as much feedback without any infringement on a duty of confidence owed by the Company to someone else.

Whistle-blower’s identities will not be disclosed without prior consent. Where concerns are unable to be resolved without revealing the identity of the whistle-blower (e.g., if their evidence is required in court), the Company will enter a dialogue with the whistle-blower concerned as to whether and how the Company can proceed.

6. Legal Protection

All employees will be protected under the Public Interest Disclosure Act 1998, where they make a protected disclosure. These are disclosures of information, which in the reasonable belief of the employee making the disclosure, cover the following employer activities:

A criminal offence has been, is being, or is likely to be committed.
A person has failed, is failing, or is likely to have failed to comply with any legal obligation to which they are subject.
A miscarriage of justice has occurred, is occurring, or is likely to occur.
The health and safety of an individual has been, is being, or is likely to be endangered.
The environment has been, is being, or is likely to be damaged.
Information relating to the above is being deliberately concealed.

7. General

Any breach of this policy will be considered serious and may result in disciplinary action up to and including termination of employment