Whistleblower Policy

About the Wisdom Properties Group Pty Ltd Whistleblower Policy

This page explains how to read this policy and describes its purpose.

1. Purpose

The purpose of this policy is to encourage reporting of wrongdoing that is of legitimate concern by providing a convenient and safe reporting mechanism, and protection for people who make serious wrongdoing disclosures.

The purpose of this policy is to provide information on:

The protections available to whistleblowers;
How and to whom an individual can make a disclosure;
How the company will support and protect whistleblowers;
How investigations into a disclosure will proceed;
How the Company will ensure fair treatment of employees who are mentioned in whistleblower disclosures; and
How this policy will be made available.

2. Scope

This policy applies to Whistleblowers, who can be current or former employees as well as others with a connection to the Wisdom Group such as contractors, suppliers, brokers and auditors or a relative or dependant of these individuals or their spouse. This policy also applies to the Wisdom Group Directors.
This policy applies to all companies in the Wisdom Group of companies, including; Wisdom Properties Group Pty Ltd, Wisdom Constructions Pty Ltd. Wisdom Real Estate Sales Pty Ltd and Wisdom Landscapes Pty Ltd.

This policy will be made available on the Wisdom Group’s intranet website.

3. Policy Statement

At Wisdom Properties Group (the Company) our Code of Conduct emphasises the importance of speaking up as a critical component of our values expectations. We are committed to fostering a culture where you feel safe to speak up on matters that concern you.

4. Matters That Should be Reported

Any matter that an individual has reasonable grounds to believe is misconduct or an improper state of affairs or circumstances, or is in breach of Company policies or in breach of the law should be reported in accordance with this Policy.

Reportable matters include any conduct that involves:

dishonest behaviour;
fraudulent activity;
unlawful, corrupt or irregular use of company funds or practices;
illegal activities (including theft, dealing in or use of illicit drugs, violence or threatened violence and criminal damage against property);
unethical behaviour, including anything that would breach the Company Code of Conduct;
improper or misleading accounting or financial reporting practices;
a breach of any legislation relating to Company operations or activities, including the Corporations Act 2001 (Cth) or Work Health and Safety Act 2011;
behaviour that is oppressive, discriminatory or grossly negligent;
an unsafe work-practice;
any behaviour that poses a serious risk to the health and safety of any person at the workplace;
a serious risk to public health, public safety or the environment; or
any other conduct which may cause loss to the Company or be otherwise detrimental to the interests of the Company.

4.1. Other Complaint Mechanisms

This policy is in addition to:

Grievance procedures for employees, which is for all staff to raise any matters they may have in relation to their work or their work environment, other persons, or decisions affecting their employment. This policy does not replace other reporting structures such as those for dispute resolution, discrimination, victimisation or matters relating to workplace bullying or harassment.
Standard complaint mechanisms for clients or volunteers
Any exercising of rights under the terms of their contract by contractors and suppliers

An exception to this is where the issue is wrongdoing of a serious nature, yet the existing reporting system failed to attend to the issue or has processed it in a substantially inappropriate, grossly unfair or heavily biased manner.

5. Making a Report

There are three reporting avenues available to those who are eligible to make a disclosure. The first option is to make a disclosure to the General Manager, Wisdom Group.

Where a Whistleblower is reluctant to make a report to Wisdom directly, additional reporting avenues are available.

Reporting avenues are:

By email to whistleblower@wisdomgroup.com.au;
By phone to Sumitomo Forestry Australia to (61) 3 9574 5500; and
Via post addressed to:

Managing Director
Sumitomo Forestry Australia
Sumitomo Forestry Australia
Suite 7, 395 Ferntree Gully Rd, Waverley VIC 3149

The Company encourages the reporting of any instances of suspected unethical, illegal, fraudulent or undesirable conduct involving the Wisdom Group of companies. The Company provides protections and measures so that those persons who make a report may do so confidentially and without fear of intimidation, disadvantage or reprisal

When a person makes a disclosure:

Their identity must remain confidential according to their wishes;
They will be protected from reprisal, discrimination, harassment or victimisation for making the disclosure;
An independent internal inquiry or investigation will be conducted;
Issues identified from the inquiry/investigation will be resolved and corrected;
They will be informed about the outcome; and
Any retaliation for having made the disclosure will be treated as serious wrongdoing under this Policy.

5.1. Confidentiality

The Company respects and protects your identity if you choose to make an anonymous report.

The Company will not disclose a Whistleblower’s identity unless:

It is necessary to further an investigation and the Whistleblower consents to the disclosure, and/or
The disclosure is required or authorised by law.

When a report is investigated it may be necessary to reveal its substance to people such as other Wisdom Properties Group personnel, external persons involved in the investigation process and, in appropriate circumstances, law enforcement agencies.

It will be necessary to disclose the facts and substance of a report to a person who may be the subject of the report as it is essential for natural justice to prevail. Although confidentiality is maintained, in some circumstances, the source of the reported issue may be obvious to a person who is the subject of a report.

Certain senior managers might be alerted to the report as part of the reporting process or if they are involved in the investigation in some manner. Any information that could potentially identify an anonymous informant will be held in the strictest confidence and will not be shared, unless the Company is compelled by law.

Wisdom Properties Group will take reasonable precautions to store any records relating to a report of wrongdoing securely and to restrict access to authorised persons only.

If you decide to disclose your identity, the Company will work to protect your identity and will outline and document who in the organisation will know you submitted your report. The Company will also take all steps necessary to ensure you do not suffer any retaliation.

It is worth noting that the Company will make every endeavour possible to investigate your report, but in some cases, there are limitations of what can be achieved if the informant decides to remain anonymous.

5.2. Retaliation
Wisdom Properties Group will not tolerate any retaliatory action or threats of retaliatory action against a Whistleblower, or against a Whistleblower’s colleagues, employer (if a contractor, consultant or supplier) or relatives.

Any such retaliatory action or victimisation in reprisal for a disclosure made under this policy will be treated as serious misconduct and will result in disciplinary action, which may include dismissal. In some circumstance it may be illegal; in which Wisdom Properties Group will notify Police.

The Company will also protect the informant, if they are an employee, from adverse action as a result of making a complaint.

6. The Investigation Process

All Whistleblower submissions will be reported to the Managing Director, Sumitomo Australia upon receipt.

Sumitomo Forestry Managing Director will, in conjunction with Wisdom Properties Group, investigate all matters reported under this policy as soon as practicable after the matter has been reported.

The Investigator (Company Representative) is appointed by the Managing Director, Sumitomo Forestry Australia, in conjunction with the General Manger of Wisdom Properties Group, and may be internal or external to Wisdom Properties Group. If the Investigator is internal, then the Investigator must have internal independence of line management in the area affected by the wrongdoing disclosure.

The investigation will be conducted in an objective and fair manner, and as is reasonable and appropriate having regard to the nature of the disclosure and the circumstances. Where a report is submitted anonymously, Wisdom Properties Group will conduct the investigation and its enquiries based on the information provided to it. However, anonymity can sometimes prevent Wisdom Properties Group from taking the issue further if Wisdom Properties Group is not able to obtain further information from the source of the report.

It is important for the Company to be transparent with our employees and outline what is the process for us to investigate a report submitted through our whistleblowing channels. Below, we have provided the different steps a company representative will go through once a report is received until the case is closed.

- Report (anonymous or otherwise) is received;
- A Company Representative is assigned to the report to assess it and confirm its receipt;
- The representative will do an initial assessment to confirm it is a valid report and request permission to investigate;
- The representative will begin their investigation. This can include corresponding with the informant if there is a channel to do this;
- The representative will investigate and update management and the informant per policy guidelines;
- Once the representative has finalised their investigation and report, management and the informant will be updated; and
- At this point, the representative will hand everything over to management for any subsequent action to take place.

6.1. Disclosure Management

Wisdom Properties Group recognises that individuals against whom a report is made must also be supported during the handling and investigation of the wrongdoing report.

Wisdom Properties Group takes reasonable steps to treat fairly any person who is the subject of a report, particularly during the assessment and investigation process.

Where a person is identified as being suspected of possible wrongdoing, but preliminary inquiries determines that the suspicion is baseless or unfounded and that no formal investigation is warranted, then the Whistleblower will be informed of this outcome and the matter laid to rest.

The Managing Director of Sumitomo Forestry Australia will decide whether or not the person named in the allegation should be informed that a suspicion was raised and found to be baseless upon preliminary review. This decision will be based on a desire to preserve the integrity of a person so named, so as to enable workplace harmony to continue unfettered and to protect the Whistleblower where it is a bona fide disclosure.

Where an investigation does not substantiate the report, the fact that the investigation has been carried out, the results of the investigation and the identity of the person who is the subject of the report must be handled confidentially. Generally, where an investigation is conducted and the Investigator believes there may be a case for an individual to respond, the Investigator must ensure that a person who is the subject of a disclosure:

- - is informed of the substance of the allegations;
  - is given a fair and reasonable opportunity to answer the allegations before the investigation is finalised;
  - has their response set out fairly in the Investigator’s report; and
  - is informed about the substance of any adverse conclusions in the Investigator’s report that affects them.

Where adverse conclusions are made in an Investigator’s report about an individual, that individual has a right to respond to those conclusions prior to any action being taken by the Company against them.

7. Breach of Policy

Breach of this policy may be regarded as misconduct, which may lead to disciplinary action (including termination of employment or engagement). An individual may also be exposed to criminal or civil liability for a breach of relevant legislation.

8. Related Policies

Other organisational policies that should be read in conjunction with this policy are:

Code of Conduct
Bullying and Harassment Policy
Conflicts of Interests Policy
Gifts & Benefits Policy
Performance Management Policy
Privacy Policy