Whistleblower Policy

Once you have made your report, it will be passed to the Whistleblower Investigations Officer (WIO). This is a person responsible for investigating a report to determine whether there is evidence in support of the matters raised or, alternatively, to refute the report.

In St John WA, the appointed WIO are the Internal Audit Lead and the Head of People Services or nominated deputies.

The WIO will assess you report to determine:

• If it falls within the Whistleblower Policy and you are eligible for protection or if the matter is more appropriately dealt with by another policy or procedure.
• If an investigation is required and, if so, who will investigate it.
• Any risks to you or your identity being revealed and how to mitigate the risks to ensure you are protected.

The WIO will notify the Whistleblower Protection Officer (WPO). The WPO has responsibility for protection and safeguarding your interests as a ‘Discloser’ and, if you are not anonymous, is responsible for keeping you updated.

All reports are redacted and anonymised before being provided to the St John WA Board Health, Safety & Culture Committee.

You can make an anonymous report or ask for your identity to be protected. If you make an anonymous report, then we will not be able to provide feedback to you and will conduct any investigation on the information provided.

Subject to compliance with legal requirements, when we receive your report, we will take reasonable steps to keep your identity confidential and reduce the risk of disclosure during an investigation. We will only share your identity as a whistleblower or information likely to reveal your identity if:

• you consent
• the concern is reported to the Australian Securities and Investment Commission, the Australian Prudential Regulation Authority, the Tax Commissioner, or the Australian Federal Police
• the concern is raised with a lawyer for the purpose of obtaining legal advice or representation.

Any disclosures of your identity or personal information likely to reveal your identity will be made on a strictly confidential basis.

It is a criminal offence, as well as a breach of the Whistleblower Policy, for a person to disclose your identity as a whistleblower, or any information that may lead to your identification as a whistleblower, other than in accordance with the Policy.

If you have concerns about this, please speak to Stopline or our Whistleblower Officers before making a report.

Please see the full Policy for more details.

If an allegation is made against you, we will support and treat you fairly by:

• Ensuring a fair and independent assessment of the allegation
• Keeping the details of the report and any allegations contained within it confidential and disclosed only to those who need to know
• Ensuring a fair and independent investigation process in accordance with Procedural Fairness (Procedural fairness relates to the fairness of the procedure in which a concern investigated is ultimately substantiated or unsubstantiated, and not the fairness in a substantive sense of the decision)
• As far as we are permitted under law, if there is evidence of wrongdoing by you, this evidence will be put to you prior to us deciding whether to take disciplinary action against you

We recognise that this situation may be stressful and remind you that all team members have access to the St John WA Employee Assistance Program. Please talk to your Whistleblower Protection Officer (WPO) about the support options available to you.

You can appeal to a WPO if you wish to raise a concern about the procedural fairness of an investigation.

You may make a report under the Whistleblower Policy if you have reasonable grounds to suspect that one of Our People or a Supplier has engaged in conduct (Disclosable Matter). A Disclosable matter is something which -

• is illegal activity (such as theft, criminal damage to property, violence, or other breaches of law) including privacy laws and competition or consumer law;
• is dishonest, Fraudulent, or corrupt including bribery or other activity in breach of the St John WA Anti-Bribery & Corruption Group Standard;
• is unethical or in breach of St John WA policy (such as dishonestly altering company records or data, adopting questionable accounting practices, inappropriately accessing patient records or wilfully breaching St John WA Code of Conduct or other policies);
• is potentially harmful to St John WA or Our People, such as unsafe work practices or wilful disregard to the safety of others in the workplace;
• amounts to an abuse of authority or a conflict of interest;
• involves harassment, discrimination, victimisation, or bullying, other than personal work-related grievances as defined in the Corporations Act;
• represents a significant danger or risk to public safety or the stability of or confidence in the financial system; or
• involves any other kind of misconduct or an improper state of affairs or circumstances, including retaliatory action against anyone raising a concern under the Whistleblower  Policy.

Disclosable maters generally do not include personal work-related grievances, such as those which only have implications for the team member and not broader issues for St John WA.

You do not have to have proof of your concerns, but you must be honest and have reasonable grounds to suspect something is wrong. It does not matter if a concern turns out to be unsubstantiated (not proven by evidence) if the disclosure has been honestly made.

It is a serious breach of this Policy to knowingly raise false information or allegations. Any instances of this will lead to disciplinary action, including dismissal.

Please see the full Policy for more details.

If an investigation is required, the Whistleblower Protection Officer (WPO) will discuss any investigation with you (unless your report is anonymous).

All investigations must be conducted by someone who is independent from the business unit and team member concerned. In most cases, this will be by a Whistleblower Investigations Officer.

If you are not satisfied with the outcome of the investigation, you can lodge a complaint with the relevant regulator such as ASIC, APRA or the ATO.

If we approve a review, the review will be conducted by someone who was not involved in the original report handling and investigation.

We are committed to providing you with a safe environment to make a report. We will take all reasonable steps to support you, including assessing the risks to you and developing an appropriate support plan with you. Team members can also access the St John WA Employee Assistance Program.

We will not tolerate any detrimental action against anyone who has made a report under the Whistleblower Policy. Detrimental action includes:

• termination of your employment
• change of your employment position or duties to your disadvantage
• discrimination between you and other team members or employees of the same employer
• Harassment or intimidation
• Harm or injury, including psychological harm
• Damage to your property; reputation; business; or financial position; or
• Other unfavourable treatment connected with making a report.

Reporting under the Whistleblower Policy does not give you immunity from any disciplinary action or from regulatory or criminal actions resulting from your wrongdoing.

Please see the full Policy for more details of what is a detrimental action and what it does not include.