Legal: Whistleblower policy - Who can I make a report to?

Provided that you have reported a concern covered by this Policy to an Eligible Recipient (being a person noted in this section), you qualify for protection as a Whistleblower under the Corporations Act, even if you report your concerns anonymously, your disclosure turns out to be incorrect or where your legal adviser had advised you that your concern is not covered by the Corporations Act.

To ensure appropriate escalation and timely investigation, we request that reports are made to any one of our Protected Disclosure Officers, listed below:

 

Reports may also be posted to c/- Level 14, Brookfield Place Tower 2, 123 St Georges Terrace, Perth, WA, 6000 (marked Private & Confidential to the attention of one of the Protected Disclosure Officers).

 

Additionally, if the Whistleblower is not comfortable or able to report their concerns under this Policy internally, a report may be made via the Loyalty Pacific Whistleblower Service, a free external hotline and reporting service independently monitored by Deloitte. Loyalty Pacific Whistleblower Service is nominated as a Protected Disclosure Officer for the purposes of this section.

The reporting options are:

• Australian Freecall: 1800 980 709
• Direct Dial (will incur a charge): +61 2 9667 3575
• Email: loyaltypacificwhistleblowerhotline@deloitte.com.au
• Website: www.loyaltypacificwhistleblowerhotline.deloitte.com.au
• Fax: +61 3 9691 8182
• Post: Loyalty Pacific Whistleblower Service, Replied Paid 12628 A’Beckett Street, Victoria 8006

 

The Loyalty Pacific Whistleblower Service will provide the details of your disclosure to an internal Protected Disclosure Officer.

However if you provide your contact details to the Loyalty Pacific Whistleblower Service, those contact details or information that may reveal your identity will only be provided to an internal Protected Disclosure Officer if you consent.

While it is Flybuys’ preference that you raise reports with the Protected Disclosure Officers referred to above, it is important to note that under the Corporations Act, you may also raise the matter with:

(a) ASIC or APRA or another body prescribed by regulation;

(b) an “officer” or “senior manager” of Flybuys or a related body corporate;

(c) an auditor, or member of an audit team conducting an audit of flybuys or a related body corporate;

(d) an actuary of Flybuys or a related body corporate; or

(e) a legal practitioner for the purposes of obtaining legal advice orlegal representation in relation to matters pertaining to this Policy.

Officer or senior manager are terms defined in the Corporations Act as “a director, or a senior manager in the company who makes, or participates in making, decisions that affect the whole, or a substantial part, of the business of the company, or who has the capacity to affect significantly the company’s financial standing.” Loyalty Pacific Pty Ltd ABN 82 057 931 334 4 In limited circumstances, a Whistleblower may be protected at law if they make a public interest disclosure or an emergency disclosure to a journalist or parliamentarian which qualifies for protection under the Corporations Act.

See Annexure A for more information.

When making a disclosure under this Policy, you should provide as much information as possible, including the details of the Reportable Conduct, people involved, dates, locations and any other evidence or material which may be relevant.

If you are unsure about whether to make a disclosure of Reportable Conduct, you may disclose in confidence to the Chief Legal Officer & Company Secretary. In the event you do not formally make a disclosure under the Policy, Flybuys may nevertheless be compelled to act on the information you have provided if that information reasonably suggests that Reportable Conduct has occurred or may occur.