Whistleblower Protection Policy

1. Purpose

Hunter Healthcare Group is committed to acting with integrity and in accordance with our purpose and values. This Whistleblower Protection Policy encourages people to identify and report misconduct, wrongdoing, or behaviour that is inconsistent with our values, without fear of reprisal.

This policy outlines how Hunter Healthcare Group supports and protects whistleblowers and complies with the Corporations Act 2001 and the Whistleblowers Protection Act 2019.  Hunter Healthcare Group will take all reasonable steps to ensure whistleblowers are protected from adverse consequences following a disclosure.

While this policy is designed to support and protect all whistleblowers, statutory protections under the Corporations Act apply only where the disclosure relates to a “disclosable matter” as defined under the legislation.

As stated in ASIC Regulatory Guide 270:

“Transparent whistleblower policies are essential to good risk management and corporate governance. They help uncover misconduct that may not otherwise be detected.”

2. Scope

This policy outlines how Hunter Healthcare Group supports and protects whistleblowers in accordance with the Corporations Act 2001.

3. Applicability

This policy applies to the following persons, whether current or former:

  • All employees (full-time, part-time, casual)
  • Members of the governing body or board
  • Volunteers
  • Contractors and consultants (whether they are employees)
  • Service providers and suppliers
  • Any other individual who has a relationship with Hunter Healthcare Group    and becomes aware of misconduct or wrongdoing

4. Definitions

Whistleblower

Any person who discloses or reports actual or suspected misconduct or wrongdoing.

Disclosable Matters

Information that concerns misconduct, or an improper state of affairs or circumstances, in relation to Hunter Healthcare Group including:

  • Conduct by the company, its officers, or employees that constitutes an offence or contravention of law
  • Conduct punishable by imprisonment for 12 months or more under Commonwealth law
  • Conduct that represents a danger to the public or the financial system

Misconduct

Illegal, unacceptable, or undesirable conduct or behaviour (actual or attempted), including but not limited to conduct that is:

  • Dishonest, unethical, fraudulent, or corrupt
  • Non-compliant with laws, regulations, or standards
  • Likely to result in financial loss
  • Inconsistent with Hunter Healthcare Group’s purpose, values, or Code of Conduct
  • Related to questionable accounting or auditing practices

5. Reportable Conduct

Whistleblowers are encouraged to report concerns relating to, but not limited to:

  • Fraud, theft, or misappropriation of funds
  • Breaches of laws or regulatory obligations
  • Abuse, neglect, or harm to consumers
  • Unsafe work practices or risks to public health and safety
  • Serious breaches of internal policies or codes of conduct
  • Corruption, bribery, or conflicts of interest
  • Attempts to conceal any of the above conduct

6. How to Make a Disclosure

Disclosures may be made verbally or in writing to:

  • A senior manager
  • A member of the governing body
  • An authorised whistleblower protection officer
  • An external regulator or authority, where permitted by law

Disclosures may be made anonymously. Whistleblowers are encouraged to provide as much information as possible to assist in the investigation.

7. Protection of Whistleblowers

Hunter Healthcare Group is committed to protecting whistleblowers and will:

  • Maintain confidentiality of the whistleblower’s identity, unless disclosure is permitted by law
  • Take all reasonable steps to prevent victimisation, harassment, discrimination, or retaliation
  • Provide support and resources to whistleblowers throughout the process
  • Ensure whistleblowers do not suffer adverse consequences as a result of making a disclosure

Any person who engages in retaliation or victimisation of a whistleblower may be subject to disciplinary action.

8. Investigation of Disclosures

All disclosures will be:

  • Taken seriously and assessed promptly
  • Investigated in a fair, independent, and confidential manner
  • Managed in accordance with procedural fairness
  • Escalated to external authorities where required by law

The whistleblower will be informed of the outcome where appropriate and lawful to do so.

9. False or Malicious Reports

This policy is intended to protect individuals who make disclosures in good faith. Deliberately false, misleading, or malicious reports may result in disciplinary action.

10. Consumer Outcome

Consumers receive quality care and services when they need them from people who are knowledgeable, capable, and caring.

11. Organisational Statement

Hunter Healthcare Group ensures that its workforce is recruited, trained, equipped, and supported to deliver the outcomes required by relevant standards and legislation.

12. Compliance and Regulation

This policy aligns with and supports compliance with:

  • Corporations Act 2001
  • Whistleblowers Protection Act 2019
  • ASIC Regulatory Guide 270
  • Standard 7(3)(d): Workforce recruitment, training, equipping and support

13. Review

This policy will be reviewed regularly and updated as required to ensure ongoing compliance with legislative and regulatory requirements.