1.    PURPOSE
The purpose of this Policy is to:
•    support and reflect PATH4 Group’s values and the PATH4 Code of Business Conduct and Ethics;
•    ensure that individuals who disclose wrongdoing can do so safely, securely, and with confidence that they will be protected and supported;
•    ensure that disclosures of wrongdoing are dealt with appropriately and promptly;
•    build confidence and trust in this Policy, its processes and procedures including by providing transparency around PATH4’s framework for receiving, handling and investigating such disclosures; and
•    deter wrongdoing and encourage disclosures of wrongdoing.
This Policy does not form part of any PATH4 employee’s terms and conditions of employment.
This Policy will be made available via the thomsonreuters.com.au website, and training will be provided to employees and officers where required.
Any questions in relation to this Policy should be directed to the PATH4 Group General Manager. Contact details for the General Manager are set out in Clause 5 of this Policy.

2. SCOPE
This Policy applies to PATH4 Group Pty Ltd and associated Franchise businesses 

3. WHO CAN MAKE A REPORT
Reports may be made under this Policy by any current or former:
•    officer or employee of PATH4 (including permanent, part-time, fixed-term or temporary, managers and directors);
•    suppliers, consultants, and contractors of PATH4 (including their employees, whether paid or unpaid);
•    associates of PATH4 (e.g. a director or company secretary of a related body corporate of PATH4); and
•    relatives, spouses and dependents of any of the above individuals.
A Discloser is any of the above individuals who makes a report in accordance with this Policy.
A Discloser may also be eligible for protection as a whistleblower under the Corporations Act 2001 (Cth) where certain requirements are met. 

4. ISSUES THAT SHOULD BE REPORTED
A Reportable Matter means any information about PATH4 (or an officer or employee of PATH4) that the Discloser has reasonable grounds to suspect concerns misconduct, or an improper state of affairs or circumstances in relation to PATH4.
This includes where the Discloser has reasonable grounds to suspect that the information indicates PATH4 or any of its employees or officers has or may have engaged in conduct that:
o    constitutes an offence against, or a contravention of the Corporations Act 2001 (Cth), the Australian Securities and Investments Commission Act 2001 (Cth); any other law of the Commonwealth that is punishable by imprisonment for a period of 12 months or more;
o    represents a danger to the public or the financial system (even if it does not involve a contravention of a particular law);
o    is a serious breach of any internal policy or code of PATH4;
o    is illegal (such as theft, use of illicit drugs, violence or criminal damage against property);
o    constitutes dishonest, fraudulent or corrupt activity, including bribery, tax evasion, money laundering or misappropriation of funds
o    constitutes a danger to health and safety at PATH4;
o    causing or threatening to cause Detriment to a Discloser who has made a report under this Policy, or who is believed or suspected to have made or be planning to make a report under this Policy; and
o    the deliberate concealment of any of the above matters.

Personal Work-Related Grievances of current or former employees are not covered under this Policy and should be reported to your line manager or HR representative. Reports about these matters may be protected under other legislation. A “Personal Work-Related Grievance” means a grievance about any matter in relation to the discloser’s employment, or former employment, having (or tending to have) implications for the discloser personally. This includes:
•    an interpersonal conflict between the discloser and another employee;
•    a decision relating to the engagement, transfer or promotion of the discloser;
•    a decision relating to the terms and conditions of engagement of the discloser; and
•    a decision to suspend or terminate the engagement of the discloser, or otherwise to discipline the discloser.

However, Personal Work-Related Grievances do not include any conduct that would be considered victimisation of an individual because they have made, may have made, or propose to make a report under this Policy, or any matter that would have significant implications for PATH4. These matters will be Reportable Matters.
Reports that are not about a Reportable Matter will not qualify for protection under the Corporations Act or the Taxation Administration Act 1953 (Cth) (although those reports may be protected under other legislation such as the Fair Work Act 2009 (Cth)).
Reasonable Grounds
A Discloser must have reasonable grounds for a report made under this Policy. A mere allegation with no supporting information is unlikely to be considered as having reasonable grounds. However, a Discloser does not need to prove their allegations. A Discloser will still qualify for protection under this Policy even if their disclosure turns out to be incorrect.

False Reports
The reporting of false information is taken very seriously by PATH4. Individuals who deliberately or knowingly report false information will not be able to access the protections available under this Policy for Disclosers, or any legal protections, and individuals who are employees, officers or contractors of PATH4 may be subject to disciplinary action or termination of engagement

5. HOW TO MAKE A REPORT
The following channels are available for reporting Reportable Matters. If a Discloser has any questions or wishes to obtain additional information before making a report, he or she should contact the company’s General Manager or obtain independent legal advice.
Reporting by Employees
Employees should first report any matters of concern to their direct line manager or human resources advisor. Where this is not appropriate, where the employee does not feel comfortable making an internal report, or where an employee has made an internal report but no action has been taken within a reasonable time, a report can be made using the reporting channels outlined below.
Report to the PATH4 General Manager 

Any Discloser may make a report directly to the General Manager:
•    Emily Monaghan at emonaghan@path4group.com phone 1300 572 732
Report to an Eligible Recipient
If a Discloser is unable to use the above channel for reporting, a report can be made to a Senior Manager assuming that is appropriate to the issue.  When making a report to a Senior Manager, the Discloser must first inform the Senior Manager that they wish to make a report under this Policy, so that the Senior Manager can make appropriate arrangements in relation to confidentiality.
In the event of a conflict of interest or other appropriate circumstance, the Senior Manager may direct the Discloser to make the report to the General Manager.
Other External Reporting Channels
PATH4 encourages employees and other Disclosers to make a report to PATH4 in the first instance, so that it can identify and address wrongdoing as early as possible. However, the Discloser may also make a report about a Reportable Matter to an external party (such as ASIC, APRA or the ATO) as set out in the Appendix.

6. CONFIDENTIALITY AND ANONYMITY
Anonymous Reports
Disclosers are encouraged (but not required) to disclose their identity when making a report. Reports may be made on an anonymous basis; however, Disclosers providing their identity will assist in:
o    monitoring their wellness and protections against Detriment (as defined in Clause 7 below); and
o    investigating their report and obtaining further information from them as is necessary to complete the investigation.
If the Discloser wishes to remain anonymous, the matter may be referred for investigation, but the investigator will be required to take all reasonable steps to reduce the risk that the Discloser will be identified as a result of the investigation.
A Discloser who wishes to remain anonymous should maintain ongoing two-way communication with PATH4, so that PATH4 can ask follow up questions or provide feedback. 
Further information on anonymity protections is set out in the Appendix.
Exceptions to Anonymity
Information about a Discloser’s identity may only be disclosed without consent in the following circumstances:
•    Where the information is disclosed to ASIC, APRA, the Australian Federal Police or to a person or body prescribed by regulations; or
•    Where the information is disclosed to a legal practitioner for the purpose of obtaining legal advice in relation to the operation of applicable whistleblowing protection laws.
Information that may be likely to lead to the identification of the Discloser may be disclosed without consent if:
o    The information does not include the Discloser’s identity;
o    all reasonable steps have been taken to reduce the risk that the Discloser will be identified from the information; and
o    It is reasonably necessary for investigating the issues raised in the report.
It is illegal for a person to identify a Discloser or disclose information that is likely to lead to the identification of a Discloser, apart from the exceptional circumstances described above. If a Discloser is concerned about possible reprisals if their identity is revealed, they should contact the General Manager  so that appropriate measures can be taken to protect them.

7. PROTECTION AND SUPPORT FOR DISCLOSERS
Prohibition of Reprisals
It is a breach of this Policy to subject a Discloser to any Detriment because they have made, or propose to make, a report under this Policy. It is also a breach of this Policy to make a threat to cause Detriment to a Discloser (or another person) in relation to a report. Any such retaliatory action will be treated as serious misconduct, and will be dealt with in accordance with PATH4’s disciplinary procedures.
“Detriment” includes (without limitation):
•    dismissal;
•    injury of an employee in his or her employment;
•    alteration of an employee’s position or duties to his or her disadvantage;
•    discrimination between an employee and other employees of the same employer;
•    harassment or intimidation;
•    harm or injury (including psychological harm);
•    damage to a person’s property; and
•    reputational, financial or any other damage to a person.
Detriment does not include administrative action that is reasonable to protect a Discloser from Detriment (for example a temporary transfer), or reasonable management action in relation to managing an employee’s work performance, if the action is in line with PATH4’s performance management framework.
If a Discloser believes they have suffered or may suffer Detriment because they have made a report under this Policy, or if any person has threatened to cause Detriment to them or another person in connection with a report, they should immediately report the matter to the General Manager.
Further information on legal protections and remedies is set out in the Appendix.
Civil, Criminal and Administrative Liability Protection
A Discloser is protected from civil, criminal and administrative liability in relation to a report made under this Policy or that is a protected disclosure under the law. This means that legal (criminal or civil) action cannot be taken against a Discloser for making a report, and they cannot be subject to disciplinary action for making a report. However, these protections do not mean that a Discloser has immunity for their own conduct that is revealed in a report.
Support for Disclosers
Additional support available for Disclosers includes but not limited to connecting the Discloser with third party support providers such as Lifeline (13 11 14) and Beyond Blue (1300 22 4636)
Use of these support services by a Discloser may require the Discloser to consent to disclosure of their identity or information that is likely to lead to the discovery of their identity.

8. INVESTIGATION OF REPORTS
Assessment of Report
The General Manager will conduct an initial assessment of a report made under this Policy to assess whether it concerns a Reportable Matter, whether a formal, in-depth investigation is required, and whether the matter may be investigated or confirmed in other ways. An investigation may not be possible if the Discloser cannot be contacted or further details cannot be obtained (for example, if a report is made anonymously and no contact details are provided).

Appointment of an Investigator
The General Manager will appoint an investigator to investigate the matter. The investigator can be:
•    an employee of PATH4 with the required skills and experience;
•    an external independent resource; or
•    another suitably qualified person,
who, in whichever case, is not implicated directly or indirectly in the report.
 
Conduct of the investigation
To the extent that they include sufficient detail and are able to be investigated, reports of Reportable Matters made under this Policy will be investigated as soon as possible after the matter has been reported. The investigator will use his or her best endeavours to conduct the investigation in a timely, thorough, confidential, objective and fair manner and as is reasonable and appropriate having regard to the nature of the Reportable Matter and all of the circumstances.
o    Where appropriate, the subject(s) of the report will be informed of the allegations and have an opportunity to respond.
o    Where appropriate, the General Manager will update the Discloser on the progress of the investigation. A Discloser must keep confidential any details of the investigation, its progress or its outcome.
o    Where appropriate, and where the identity of the Discloser is known, the WPO will inform the Discloser of the outcome of an investigation.
Investigation outcomes
The method of documenting and reporting the findings of an investigation will depend on the nature of the report. Where a formal investigation is conducted, the investigator will provide a report to the General Manager documenting the investigator’s findings. This report must be kept strictly confidential and disclosed only to those who have a need to know the information.
The outcome of the investigation may result in disciplinary action for officers and employees up to and including dismissal without notice. Serious criminal matters will be reported to the police or the appropriate regulatory authorities.
Confidentiality
Participants in the investigation of any report under this Policy are required to keep confidential all relevant information. All paper and electronic documents and other materials relating to reports will be stored securely, and access to all information relating to a report will be limited to those directly involved in managing and investigating the report.
Disclosers should also keep confidential the fact that they have made a report, and the content of the report, as well as all information relating to an investigation of their report.

9. FAIR TREATMENT OF PERSONS IMPLICATED
Any reports made under this Policy that mention or implicate an employee or officer of PATH4 must be kept confidential, even if the Discloser has consented to the disclosure of their identity. Reports should only be disclosed to those persons who have a need to know the information for the proper performance of their functions under this Policy, or for the proper investigation of the report.
No action will be taken against employees or officers who are mentioned or implicated in a report under this Policy until an investigation has determined whether any allegations against them are substantiated. However, an employee or officer who is implicated may be temporarily stood down on full pay whilst an investigation is in process, or may be temporarily transferred to another office, department or workplace, if appropriate in the circumstances, while the investigation is continuing. If the investigation determines that the allegations are not substantiated, the employee or officer must be immediately reinstated to full duties.
An employee or officer who is implicated in a disclosure has a right to be informed of the allegations against them, and must be given an opportunity to respond to those allegations and provide additional information, if relevant, in the course of an investigation into those allegations (subject to the Discloser’s right to anonymity). An employee or officer who is implicated in a report will be informed of the outcome of any investigation.
Support available for persons mentioned or implicated in a report under this Policy includes connecting the person with third party support providers such as Lifeline (13 11 14) and Beyond Blue (1300 22 4636).

10. REVIEW AND MONITORING
PATH4 shall review this Policy, and its whistleblowing processes, on a periodic basis to ensure that it is operating effectively, and to rectify any issues identified in the review.
 
APPENDIX
Protections for Whistleblowers under the Corporations Act
•    A Discloser may qualify for protection as a whistleblower under the Corporations Act 2001 (Cth) if:
o    they are an ‘eligible whistleblower’ in relation to PATH4, and:
o    They have made a disclosure of information relating to a ‘disclosable matter’ directly to an ‘eligible recipient, or to The Australian Securities and Investments Commission (ASIC), the Australian Prudential Regulation Authority (APRA), the Australian Tax Office (ATO) or another Commonwealth body prescribed by regulation; or
o    They have made a disclosure to a legal practitioner for the purposes of obtaining legal advice or legal representation about the operation of the whistleblower provisions in the Corporations Act (even in the event that the legal practitioner concludes that a disclosure does not relate to a ‘disclosable matter’); or
o    They have made an ‘emergency disclosure’ or a ‘public interest disclosure’.
Public interest disclosures and emergency disclosures
Disclosures can be made to a journalist or a parliamentarian under certain circumstances and qualify for protection under the Corporations Act. These kinds of disclosures must meet several legal requirements, as described below, in order for the discloser to be subject to the whistleblower protections under the law. A discloser should obtain independent legal advice to ensure that they understand the criteria for making an emergency disclosure or a public interest disclosure that qualifies for protection.
An Emergency Disclosure is the disclosure of information to a journalist or parliamentarian, where:
•    the discloser has previously made a disclosure of the information to ASIC, APRA or another Commonwealth body prescribed by regulation;
•    the discloser has reasonable grounds to believe that the information concerns a substantial and imminent danger to the health or safety of one or more persons or to the natural environment;
•    before making the emergency disclosure, the discloser has given written notice to the body to which the previous disclosure was made that:
o    includes sufficient information to identify the previous disclosure; and
o    states that the discloser intends to make an emergency disclosure; and
•    the extent of the information disclosed in the emergency disclosure is no greater than is necessary to inform the journalist or parliamentarian of the substantial and imminent danger.
A Public Interest Disclosure is the disclosure of information to a journalist or a parliamentarian, where:
•    at least 90 days have passed since the discloser made the disclosure to ASIC, APRA or another Commonwealth body prescribed by regulation;
•    the discloser does not have reasonable grounds to believe that action is being, or has been taken, in relation to their disclosure;
•    the discloser has reasonable grounds to believe that making a further disclosure of the information is in the public interest; and
•    before making the public interest disclosure, the discloser has given written notice to the body to which the previous disclosure was made that:
o    includes sufficient information to identify the previous disclosure; and
o    states that the discloser intends to make a public interest disclosure.
Legal Protections
The following protections are available to whistleblowers who make a protected disclosure under the Corporations Act or the Taxation Administration Act (whether that disclosure is made internally, or to an external body such as ASIC, APRA, a legal practitioner or is a public interest or an emergency disclosure):
•    Protection of the whistleblower’s identity, if he or she wishes to remain anonymous;
•    Protection from Detriment because of making a protected disclosure;
•    The right to claim compensation for loss, damage or injury caused to the Whistleblower because of a protected disclosure;
•    Protection from civil, criminal and administrative liability because of making the protected disclosure.
Anonymous Reports
A report can be made anonymously and still be protected under the Corporations Act. A Whistleblower can choose to remain anonymous while making a disclosure, over the course of the investigation and after the investigation is finalised. A Whistleblower can refuse to answer questions that they feel could reveal their identity at any time, including during follow-up conversations. However, the Whistleblower should be aware that the absence of facts pertinent to the alleged misconduct may prevent PATH4 from conducting a thorough investigation.
Other measures that may be taken to preserve the Whistleblower’s identity include:
•    Communicating through an anonymous e-mail address;
•    Using a pseudonym for the Whistleblower;
•    Referring to the Whistleblower in a gender neutral context;
•    Ensuring that all documents relating to a disclosure are handled and stored securely; and
•    Limiting access to information about a disclosure to those who have a need to know, for the purpose of handling or investigating the disclosure, or protecting the Whistleblower.
The Whistleblower should be aware that anonymity may not be able to be maintained in circumstances where the Whistleblower has informed other people about the disclosure, either before or after making a disclosure under this Policy.
Legal Remedies
A Whistleblower that suffers loss, damage or injury because of a protected disclosure may seek compensation and other remedies through the courts. A Whistleblower should seek independent legal advice if they wish to obtain such a remedy. A Whistleblower may also contact regulatory bodies such as ASIC or APRA if they believe that they have suffered Detriment due to making a report about a disclosable matter, or if there has been a breach of confidentiality such as a disclosure of their identity without their consent.