This Whistleblower Policy has been developed because whistleblowing can protect Pioneers of Australia (PoA) and its related entities from significant legal, financial, cultural and reputational risks. It provides a process for individuals to raise matters that may otherwise go undiscovered. Undetected misconduct within an organisation can impact trust of our members, financial and prayer supporters, employees, volunteers and all PoA related parties.
This policy ensures compliance with ACNC governance standards and whistleblower protection regime of the Corporations Act 2001 (Corporations Act).
Pioneers Ministries Foundation is a company limited by guarantee and a related entity to Pioneers of Australia (PoA).
This policy will be made available to officers and employees at the time of their induction with PoA.
A copy of this policy will be included with all PoA policies and procedures.
Pioneers of Australia (PoA) and its related entities are committed to the highest ethical standards in the conduct of all its operations and relationships. PoA is focused on detecting and eliminating misconduct and promoting and supporting a culture of honesty, integrity, compliance and sound corporate governance.
As followers of Christ, we are to speak truthfully and lovingly without intimidation or manipulation even when confrontation or correction is required (Eph 4:15). God is for those who speak truth even when it is difficult to do so.
The objective of this policy is to encourage reporting of wrongdoing that is of legitimate concern by providing a convenient and safe reporting mechanism, and protection for people who make disclosures of serious wrongdoing.
This Policy applies to the PoA Board, personnel including staff and field members, volunteers and interns. It extends to suppliers. contractors, consultants, service providers (their employees and subcontractors) and to all those who have a business relationship with PoA.
This policy is to be followed in reporting any instances of suspected behaviour which is unethical, illegal, fraudulent or undesirable conduct involving PoA.
Terms used in this Policy are:
- Whistleblowing – The act of disclosing actual or suspected wrongdoing or misconduct within an organisation. Whistleblowing does not include matters of personal grievances or workplace complaints and concerns which would usually be resolved through staff grievance and dispute resolution policy
- Whistleblower – A person who reports known or reasonably suspected wrongdoing or misconduct within the organisation
- Wrongdoing/Misconduct – An act or omission that involves a breach of law, organisational policy, or generally recognised principles of ethics
Roles and Responsibilities
Every person associated with PoA has a role and responsibility in ensuring PoA is run ethically and in accordance with its rules and policies. Where matters related to breaches or wrongdoing are identified they should be raised as soon as possible.
In instances where a person has concerns about making a report, reports can be made anonymously.
Protection is available to Whistleblowers who disclose wrongdoing that is serious in nature; made in good faith; and made with reasonable grounds to believe it is true.
Protection is not available where the disclosure is vexatious in nature with no substance. This will be treated in the same manner as a false report and may itself constitute wrongdoing.
A Whistleblower must provide information to assist any inquiry or investigation of the wrongdoing disclosed. If the whistleblower does not share their identity, PoA or the authority to whom the misconduct was reported will assess the concern in the same way as if they had revealed their identity. However, there may be some practical limitations in conducting the investigation.
- Whistleblower Protection Officer (WPO)
PoA board will appoint a Whistleblower Protection Officer (WPO) who is authorised to receive whistleblower disclosures, to support and to provide protection to the Whistleblower according to this policy.
In cases where the Whistleblower does not feel safe to speak to the WPO they may seek to discuss the matter with the PoA Board Chair.
If the misconduct cannot be raised with anyone associated with PoA, the Whistleblower may approach Australian Securities and Investments Commission (ASIC) or the Australian Prudential Regulation Authority (APRA) or their lawyer.
The WPO will provide mentoring and other support deemed necessary. The WPO is responsible for keeping the Whistleblower informed of the progress and outcomes of the investigation subject to considerations of privacy of those against whom a disclosure has been made.
- Whistleblower Investigation Officer (WIO)
The Whistleblower Investigation Officer (WIO) will be appointed jointly by the PoA Board Chair and the WPO. This Officer may be internal or external to PoA. The WIO will have internal independence of line management in the area affected by the wrongdoing disclosure.
The WIO is responsible for receiving whistleblower disclosures of wrongdoing and overseeing its investigation and resolution.
The WIO may consult with other officers in PoA to assist in the investigation and may seek the advice of internal or external experts as required.
The WIO must, after reasonable assessment, be satisfied that action taken in response to the investigation is appropriate to the circumstances and ensure that all investigations are carried out in line with the principle of procedural fairness.
Reporting and Investigation
Any information provided to PoA or an external body as referred to in this policy may be used in the assessment of an investigation or in ascertaining appropriate action.
When a matter of misconduct is reported, the Whistleblower should provide as much information as possible. Information such as dates, times, location, individuals involved, other witnesses, physical evidence (e.g. documents, images) and any other general information that may be helpful to assist the organisation to determine how to take appropriate action.
If PoA or the external authority to which the matter was reported determines that it should be investigated, the investigation may be conducted in line with this policy and may involve WPO, WIO and the PoA Board Chair. All investigations will be conducted in a manner that is procedurally fair, confidential, conducted without bias and in a timely manner.
At the end of an investigation, the Whisleblower will be informed of the outcome of the investigation. PoA may in certain circumstances, whether required by law or in its discretion, inform other external regulatory bodies or the relevant authorities of any contents of the investigation.
The investigation will conclude with a report from the WIO or another investigator involved in relation to matters reported externally. The report will include findings on the allegations and a summary of the evidence on which the findings were based. To the extent permitted under applicable laws, the WIO may inform the Whistleblower and/or a person against whom allegations were made, of the findings.
PoA is committed to protecting and respecting the rights of Whistleblowers who report wrongdoing in good faith.
PoA will take reasonable precautions to store any records relating to a report of wrongdoing securely and to restrict access to authorised persons only. Unauthorised disclosure of information that could prejudice confidentiality and identify a Whistleblower will be regarded seriously and may result in disciplinary action.
PoA strictly prohibits all forms of detrimental conduct against people who are involved in an investigation of a whistleblower disclosure in response to their involvement in that investigation.
The Whistleblower will have access to the assistance of the WPO as provided in this policy. Any concerns may be escalated by the Whistleblower directly to the PoA Board Chair if the WPO has not adequately resolved a complaint regarding detrimental conduct or this policy has not been followed in the investigation process.
PoA may not be able to provide the same practical support to non-employees or other associated parties that it provides to current employees or relationships present at the time of reporting. Therefore, the processes in this policy will be adapted and applied to the extent reasonably possible.
It is important to understand that if a person reports a matter of wrongdoing, they are not exempt from the consequences of their own misconduct.
PoA Board Chair: email@example.com
Whistleblower Protection Officer (WPO): firstname.lastname@example.org