Whistleblower Policy

Updated in March 2026

1. Purpose and Scope

AHRI’s Whistleblower Policy is designed to assist in our ability to provide a supportive and transparent environment. This Policy will ensure that our Employees can raise concerns about Reportable Conduct without fear of victimisation, harassment, or discrimination.

We are committed to addressing concerns fairly, promptly, sensitively, and confidentially as much as the law allows.

2. Scope

This Policy does not cover matters that are regarded as personal work-related grievances, which should be reported as per the Workplace Bullying and Harassment Prevention Policy and/or the Grievance Policy.

A disclosure about work-related grievances may qualify for protection where the disclosure:

  1. also includes information about Reportable Conduct (as defined in section 5 below);
  2. suffers from, or is threatened with, detriment for making a disclosure;
  3. seeks legal advice about the operation of whistleblower protections;
  4. relates to the breach of employment (or other) laws punishable by imprisonment for a period of 12 months or more;
  5. relates to conduct that represents a danger to the public; or
  6. relates to information that suggests misconduct beyond the discloser’s own personal circumstances.

3. Application

AHRI Employees who become aware of known, suspected, or potential cases of Reportable Conduct must make a report under this Policy or under other applicable policies as a matter of priority.

Any Workplace participants may raise concerns regarding reportable conduct and are considered as eligible whistleblowers.

Eligible whistleblowers (as defined in the Corporations Act section 1317AAA) include:

  1. current and past executive and non-executive directors,
  2. officers,
  3. employees (full-time, part-time, casual, fixed term),
  4. AHRI volunteers
  5. contractors
  6. sub-contractors
  7. suppliers
  8. associates
  9. service providers (such as consultants) and their Employees as well as their relatives and dependants.

4. Matters that should be reported

If an AHRI employee suspects misconduct in relation to the conduct of AHRI’s representatives (officers or employees) they can report the matter in accordance with this policy.

Reportable Conduct may involves, but is not limited to:

  • misconduct such as a breach of AHRI’s code of conduct or other policies and procedures or an improper state of affairs;
  • dishonest behaviour;
  • fraudulent activity;
  • unlawful practices;
  • unlawful, corrupt or irregular use of company funds;
  • illegal activities that may constitute an indictable offence under Federal, State, or Territory Law;
  • unethical behaviour, including anything that would breach our Anti-Bribery & Anti-Corruption Policy;
  • improper or misleading accounting or financial reporting practices;
  • a breach of any legislation relating to our operations or activities;
  • a matter set out in section 2 above; or
  • tax avoidance behaviour and other taxation-related impropriety – this is discussed further in section 6.

A disclosure which does not relate to Reportable Conduct will not qualify for protection under the Corporations Act 2001 (Cth) (Corporations Act) or the Taxation Administration Act 1953 (Cth) (Taxation Administration Act) (as relevant). However, a disclosure made to a legal practitioner for the purposes of obtaining legal advice will always be protected under the whistleblower protections of the Corporations Act.

5. Tax Whistleblowers

A disclosure in relation to tax avoidance behaviour and other taxation-related impropriety may be made to our auditors in addition to a legal practitioner or any of our directors, officers or senior management employees. A disclosure may also be made to the Australian Taxation Office where the individual believes the information to be disclosed may assist the Commissioner of Taxation in performing its duties and functions.

AHRI Personnel who make a disclosure relating to our tax affairs will qualify for whistleblower protections under the Taxation Administration Act as discussed in section 7.

6. Making a report

Internal Reporting

Reportable Conduct can be brought to the attention of one of AHRIs Protected Disclosure Officers. Protected Disclosure Officers are required to comply with the terms of this Policy, including keeping your identity confidential (subject to applicable laws) and provide necessary support during the investigation.

  • Our Protected Disclosure Officers are our CEO, CFO and for people-related matters, the GM, People & Culture.
  • Internal reports can be made via email at [email protected].
External Reporting

If an internal report is not appropriate or desired, a report can be made to AHRI’s external independent whistleblowing service provider, Yourcall.

How reports made via Your Call are handled

Online 24 hours a day /7 days a weekwww.yourcall.com.au/AHRI
Telephone 7am – midnight AEST, business days1300 790 228 AU

It is possible to:

  • make an external report anonymously or share your identity by consent.
  • securely upload any relevant documentation or material needed.
  • remain in contact and receive updates about the handling of the report via Your Call’s online message board.

With consent, a report will be provided to AHRI’s nominated whistleblower officers so that it can be managed in accordance with this policy. Alternatively, it can remain anonymous, and an identity will not be provided by Your Call to AHRI without consent. Your Call will not investigate this scenario.

National Relay Service

If you are deaf, or have a hearing or speech impairment, you can contact Your Call online or through the National Relay Service at https://www.accesshub.gov.au and requesting Your Call’s hotline 1300 790 228.
If you have difficulty speaking or understanding English, Your Call can be contacted through the Translating and Interpreting Service (TIS) 131 450 and asking for Your Call on 1300 790 228.

Other Avenues of External Reporting

You may also report to officers and senior managers of our related entities, audit or actuarial teams (as applicable), a legal practitioner and to the Australian Securities and Investment Commission (ASIC) and other Commonwealth authorities.

However, we encourage you to use our internal processes in the first instance.

A disclosure of Reportable Conduct which is not made to a recipient specified in this section or section 9 below will not qualify for protection under the Corporations Act or the Taxation Administration Act.

Anonymity

A report can be made anonymously – Protected Disclosure Officers will keep the identity of all reporters confidential (subject to applicable laws). However, it may be challenging to investigate anonymous reports thoroughly. If authorities take further legal action in relation to the reported matter, it may become necessary for a reporter to identify themselves to these authorities. Anonymous reporters will qualify for protection under the Corporations Act, and AHRI will continue to take all reasonable steps to ensure that the reporter is treated fairly and protected against discrimination or detriment in respect of their employment.

7. Protection for Whistleblowers

Eligible whistleblowers who report Disclosable matters in accordance with the legislation and this policy are entitled to certain legal protections.

AHRI employees who report Disclosable matters in accordance with this Policy (Whistleblower) will not be victimised, discriminated against or be disadvantaged in their employment in any way, even if the report is subsequently determined to be incorrect or not able to be substantiated.

This Policy may not protect the Whistleblower from liability if they are found to have been involved in or connected to the Reportable Conduct or if the complaint is found to be vexatious.

Confidentiality and protection of identity

AHRIs Protected Disclosure Officers are legally prohibited from disclosing any information that might identify a complainant without consent, unless required by law. Any disclosure will be done on a strictly confidential basis. However, the Protected Disclosure Officer can disclose the complaint without your consent to ASIC, APRA or the Australian Federal Police, to an Australian legal practitioner for the purposes of obtaining legal advice, or otherwise as permitted by law.

Protection of files and records

All files and records created from an investigation into Reportable Conduct reported under this Policy will be securely stored and retained. No information pertaining to the Reportable Conduct will be released to any person not involved in the investigation (other than to our senior managers or directors requiring access to action the report or for corporate governance purposes) without the relevant Protected Disclosure Officer’s authority and consent.

Support for Whistleblowers

AHRI is committed to supporting their Employees who wish to make a report under this Policy. If a report under this Policy is being made in person, a support person can be requested. AHRI will take all reasonable steps to ensure that Employee who makes a report of Reportable Conduct will receive appropriate support and follow up.

Additional support is available via:

  • AHRIs Employee Assistance Program (EAP). Career Money Life is a confidential counselling service offered to all AHRI employees and immediate family members. Career Money Life can be accessed by calling 1300 344 996 or [email protected]
  • AHRIs People & Culture Team; or
  • Independent support service providers such as Lifeline 13 11 14 and Beyond Blue.
Fairness

AHRI Employees who make a report under this Policy will not suffer victimisation or adverse treatment as a result. Victimisation or adverse treatment may include actual or threatened:

  • dismissal, demotion, suspension or alteration of an employee’s position;
  • discrimination between AHRI Personnel;
  • damage to property, reputation or financial position; or
  • harassment, intimidation, harm or injury.

AHRI does not tolerate any form of unfair treatment, threat, retaliation or other action against individuals who have made or assisted in the making of a report under this Policy.

Behaviour that could be considered as threatening, retaliation or other detrimental action will be investigated and if substantiated, will be managed appropriately.

Whistleblowers are entitled to seek compensation and other remedies for loss, damage or injury suffered as a result of a disclosure or if we have failed to take reasonable precautions and exercise due diligence to prevent the detrimental conduct from occurring.

False reports

Protection is not available where the disclosure is:

  • Trivial or vexatious in nature with no substance. This will be treated in the same manner as a false report and may in itself constitute wrongdoing
  • Unsubstantiated allegations which are found to have been maliciously or knowingly to be false.

Anyone who knowingly makes a false report, or who otherwise fails to act honestly with reasonable belief in respect of the report may be subject to disciplinary action, including dismissal (in the case of employees) or professional conduct sanction (in the case of non-employees). The disciplinary action or sanction will depend on the severity, nature and circumstances of the false report.

Other Avenues of External Reporting

In circumstances where you make a report of Reportable Conduct to ASIC, APRA or a prescribed Commonwealth authority and:

  • you have reasonable grounds to believe the report concerns a substantial and imminent danger to the health and safety of one or more persons or the natural environment; or
  • at least 90 days have elapsed since the date of that report and you do not have reasonable grounds to believe that action has been taken in respect of that report (providing that you have contacted the person to whom the report has been made to check on the status of the investigation) and you have reasonable grounds to believe that making a further disclosure would be in the public interest,
    a further report may be made to a member of parliament or journalist in certain circumstances as set out in the whistleblower legislation.

A disclosure may also be made to the Australian Taxation Office if you believe that the information to be disclosed may assist the Commissioner of Taxation in performing its duties and functions.

We will take reasonable steps to ensure that a Whistleblower is not victimised as a result of making a protected emergency report.

8. Reportable Conduct Investigations

All Reportable Conduct reported under this Policy will be investigated as soon as possible after the matter has been reported. The relevant Protected Disclosure Officer will have responsibility and oversight for the investigation (unless we determine that a more suited Protected Disclosure Officer should take control of the investigation). The Protected Disclosure Officer may, subject to confidentiality and Whistleblower’s consent requirements, appoint a person internal or external to us to assist in the investigation of a matter raised in a report. Where appropriate, we will provide regular feedback to the Whistleblower regarding the investigation’s progress and/or outcome (subject to considerations of the privacy and confidentiality considerations of those against whom allegations are made).

The investigation will be conducted in an objective and fair manner. At the conclusion of an investigation into Reportable Conduct, a confidential report will be provided to AHRI’s Chief Executive Officer or Board Chair, depending on the circumstances. A copy of the report will not be shared with the Whistleblower.

Substantiated reports of Reportable Conduct may result in disciplinary action in respect of the persons against whom substantiated allegations are made, up to and including termination of employment or engagement.

9. Training

This Policy (or a summary of it) will be circulated to AHRI Employees, and available via SharePoint. It will be made available to the public via AHRI’s website. All reasonable steps will be taken to ensure that AHRI Employees are aware of, and understand this Policy, and the types of behaviour or scenarios that are reportable, including through internal communications and training.

Any disclosures of Reportable Conduct will be retained in AHRI’s confidential ‘Whistleblowing Register’ which will be maintained by the company secretary.

10. Review of this policy

This Policy will be reviewed every two years to ensure that it remains effective and relevant, and that it is continues to comply with all relevant legislative requirements.