1. Purpose

Reledev Australia is committed to accountability and transparency. The purpose of this policy is to provide a supportive work relationship environment where misconduct within or by Reledev Australia can be raised without fear of retribution.

This is achieved by:

  • encouraging the reporting of serious misconduct
  • providing protected misconduct reporting alternatives to remove inhibitions that may impede such disclosures
  • establishing procedures that enable:
    • protection for those that make serious misconduct disclosures
    • independent internal inquiry/investigation of disclosures made
    • resolution of the issue(s) identified

This policy is guided by the UNICEF Australia’s Whistleblower Protection Policy

  1. Scope

This policy applies to directors, employees, volunteers, contractors and consultants. It also applies to a person or organisation with a relationship with Reledev Australia who reports serious misconduct within or by a Reledev Australia employee/s.

3.   Definitions and descriptions

3.1 Definitions

  • Whistleblowing is: The disclosure by or for a witness, of actual or suspected misconduct in an organisation that reveals fraud, corruption, illegal activities, gross mismanagement, malpractice or any other serious wrongdoing.
  • Whistleblower is: A person who reports serious misconduct in accordance with this policy

3.2   Descriptions of misconduct for this policy

Misconduct includes behaviour that:

  • is fraudulent or corrupt
  • is illegal
  • is unethical, such as acting dishonestly; altering company records; wilfully making false entries in official records; engaging in questionable accounting practices; or wilfully breaching Reledev Australia’s code of ethics and of the ACFID Code of Conduct
  • is potentially damaging to Reledev Australia, such as maladministration
  • is seriously harmful or potentially seriously harmful to a Reledev Australia employee or volunteer such as deliberate unsafe work practice or wilful disregard to the safety of others in the workplace
  • may cause serious financial or non-financial loss to Reledev Australia; or damage its reputation; or be otherwise seriously contrary to Reledev Australia’s Whistleblowing policy
  • involves any other kind of serious impropriety including retaliatory action against a whistleblower for having made a wrongdoing disclosure

Training regarding policy

  • All Reledev Australia staff will be made aware of this policy and their responsibilities to report wrongdoing to the Manager. It is the responsibility of the Manager to ensure all staff are adequately trained in understanding, identifying and (where possible) mitigating any activity that may breach the definitions of fraudulent or corrupt behaviour.
  • Reledev stakeholders will be notified of the Whistleblower policy via the Reledev Australia website.
  1. Policy Statement

Reledev Australia is committed to the highest standards of legal, ethical and moral behaviour. It recognises that people who have a working relationship with Reledev Australia are often the first to realise there may be concerns. When a person makes such a disclosure they are entitled to expect that:

  • their identity remains confidential at all times to the extent permitted by law or is practical in the circumstances,
  • They will be protected from reprisal, harassment or victimisation for making the report,
  • Should retaliation occur for having made the disclosure then Reledev Australia will treat it as serious wrongdoing under this Policy.

Therefore, there should be no fear of appearing disloyal or concern about being victimised or the subject of other reprisals, about reporting this misconduct.  No person will be personally disadvantaged for reporting a wrongdoing. Not only may this misconduct be illegal, but it may directly oppose the values and mission of Reledev Australia.

Reledev Australia is committed to maintaining an environment where legitimate concerns are able to be reported without fear of retaliatory action or retribution.

Manual of Procedures for the Whistleblower policy

Reledev Australia is committed to the highest standards of legal, ethical and moral behaviour. It recognises that people who have a working relationship with Reledev Australia are often the first to realise there may be concerns. When a person makes such a disclosure they are entitled to expect that:

  • their identity remains confidential at all times to the extent permitted by law or is practical in the circumstances,
  • They will be protected from reprisal, harassment or victimisation for making the report,
  • Should retaliation occur for having made the disclosure then Reledev Australia will treat it as serious wrongdoing under this Policy.

This Manual comprises the guidelines for the implementation of the Whistleblower policy. It includes:

  1. Information / Disclosure / Training regarding policy
  • All Reledev Australia staff will be made aware of this policy and their responsibilities to report wrongdoing to the Manager. It is the responsibility of the Manager to ensure all staff are adequately trained in understanding, identifying and (where possible) mitigating any activity that may breach the definitions of fraudulent or corrupt behaviour.
  • Reledev stakeholders will be notified of the Whistleblower policy via the Reledev Australia website.
  1. Conditions for reporting:
  • A person considering making a whistleblower report is obliged to act in good faith and have reasonable grounds for believing the disclosure is reportable wrongdoing.
  1. Reporting Procedures
  • A whistleblower should report instances of, or suspicions of misconduct to Contact Point 1: the Reledev Australia’s Manager. Reports must be made in good-faith and be as thorough as is possible. False of malicious allegations may result in disciplinary actions.
  • Where it is not possible or appropriate to report suspicion of misconduct to the Manager (Contact Point 1), reports should be raised directly to a Director of the Board (Contact Point 2) – Maria Vega Flores (floresmariavega@gmail.com).
  • If the report is lodged with Contact Point 1, the officer will contact the Vice Chairperson. Both parties will agree on the appointment of an appropriate delegate, who is not implicated in the report, to lead the investigation.
  • If the report is lodged with Contact Point 2, the officer will contact the Chairperson of the board. Both parties will agree on the appointment of an appropriate delegate, who is not implicated in the report, to lead the investigation.
  • The individual who leads the investigation will be referred to as the Whistleblower Protection Officer and should either a:
    • qualified internal investigator who is independent of the area where the wrongdoing is alleged to have occurred, or
    • qualified external investigator independent of Reledev Australia where considered necessary
  • The responsibilities of the appointed investigator include the assurance that action taken in response to the inquiry is appropriate to the circumstances and retaliatory action will not been taken against the person who made the disclosure.
  • Once the Whistleblower Protection Officer is appointed, the Contact Point will notify the Board of Directors the details and process of the investigation to be undertaken.
  • The investigator has direct, unfettered access to independent financial, legal and operational advisers as required, and a direct line of reporting to the relevant Contact Point, as may be required to satisfy the objectives of this Policy.
  • The Whistleblower Protection Officer must keep the Contact Point regularly informed of the investigation progress.
  • The Whistleblower Protection Officer is also responsible for keeping the Whistleblower informed of the progress and outcomes of the inquiry/investigation subject to considerations of privacy of those against whom the allegations have been made.
  • The internal investigator must have internal independence of line management of the area affected by the wrongdoing disclosure. The internal investigator is authorised to apply the powers granted by the Board of Directors.
  • The investigator may second the expertise of other officers in Reledev Australia to assist in the investigation and may seek the advice of internal or external experts as required.
  1. Obligations
  • A Whistleblower must provide information to assist any inquiry/investigation of the wrongdoing disclosed.
  • Even though a whistleblower may be implicated in the wrongdoing they must not be subjected to any actual or threatened retaliatory action or victimisation in reprisal for making a report under this policy.
  • It is important to note that making a report may not protect the whistle-blower from the consequences flowing from involvement in the wrongdoing itself. A person’s liability for their own conduct is not affected by their reporting of that conduct under this policy. However active cooperation in the investigation, an admission and remorse may be taken into account when considering disciplinary or other action.
  1. Supporting Documents
  • Reledev Fraud Risk management policy
  • Reledev Complaints policy and procedures
  • Reledev Professional Conduct Guidelines