Whistleblowers are protected from any conduct (including threats, whether express or implied) that causes them detriment in relation to the disclosure including where the person that is causing the detriment believes or suspects that the Whistleblower may have made or proposes to make a disclosure that qualifies for protection.
Detrimental conduct includes dismissal, injury in employment, alteration of an employee’s position or duties to their disadvantage; demotion, harassment, intimidation, harm or injury including psychological harm; discrimination, disciplinary action or damage to reputation, including damage to business or financial position; bias, threats or other unfavourable treatment connected with making a report.
Detrimental conduct does not include administrative action that is reasonable to protect a Whistleblower from detriment or management of unsatisfactory work performance where the action is in line with flybuys’ performance management framework.
flybuys is committed to making sure that a person is treated fairly and does not suffer detriment for making a disclosure under this Policy.
flybuys may take the following measures to ensure that a person who has made a disclosure under this Policy is protected from detriment:
(a) allow the Whistleblower to perform duties at another location;
(b) reassign or relocate the Whistleblower to another role at the same or substantially the same level;
(c) make modifications to the Whistleblower’s workplace or way they perform their duties;
(d) develop processes for ensuring that management are aware of their responsibilities to maintain the confidentiality of disclosure, address the risks of isolation or harassment, manage conflicts, and ensure fairness when managing the performance of, or taking other management action relating to, a Whistleblower;
(e) develop procedures for how a Whistleblower can make a complaint if they believe they have suffered detriment and the actions flybuys will take in response to such complaints;
(f) intervene where detrimental conduct has already occurred, including investigating and taking disciplinary action, allowing the Whistleblower to take extended leave, develop a career development plan for the Whistleblower that includes new training and career opportunities, or other compensation or remedies.
The Corporations Act imposes civil and criminal sanctions on persons who causes detriment to the Whistleblower.