1. Terri Bell & Co Pty Limited (the “Company”) is committed to a culture of good commercial practice and highly ethical behaviour.
  2. The Company’s ethical values are set out in the Company’s Employee Handbook.


  1. This policy 1  applies to all current and former employees, volunteers and suppliers of the Company. Other persons (such as third party contractors, customers, relatives, dependants or dependants of spouses of any employee) may use the procedures in this policy.
  2. In this policy, the people this policy applies to are referred to as an “eligible person” (“Eligible Person”).


  1. The objectives of this policy are to:
    1. encourage every Eligible Person to disclose any malpractice, misconduct or conflicts of interest of which they become aware;
    2. provide protection for every Eligible Person who disclose allegations of malpractice, misconduct or conflicts of interest
    3. indicate when such disclosures will be investigated.

Whistleblower protection

  1. This policy is designed to give guidance so that honesty and integrity are maintained at all times at the Company.
  2. To the maximum extent practicable, a person who genuinely discloses an allegation or concern about compliance with laws or other standards of behaviour (“Whistleblower”) will be protected from any adverse action (such as dismissal, demotion, suspension, harassment, or other forms of discrimination) because they have raised such allegations. Subject to this policy, a Whistleblower is protected, even if the allegations prove to be incorrect or unsubstantiated (although a person who maliciously or vexatiously makes disclosures or makes false disclosures may be subject to disciplinary action).
  3. Employees who participate, or assist in, an investigation involving reportable conduct will also be protected. Every effort will be made to protect the anonymity of the Whistleblower, however, there may be situations where anonymity cannot be guaranteed. In such situations, the Whistleblower will be informed.

Reportable conduct

  1. Reportable conduct that can be the subjected of a protected Whistleblower report is anything the Eligible Person has reasonable grounds to suspect concerns misconduct or an improper state of affair or circumstances. Examples of things that may be considered misconduct or an improper state of affair or circumstances include:
    1. dishonesty
    2. fraud;
    3. corruption
    4. illegal activities (including theft, drug sale/use, violence, threatened violence, or criminal damage against The Company’s assets/property);
    5. discrimination, vilification, sexual harassment, harassment, bullying and victimisation;
    6. acts or omissions in breach of commonwealth or state legislation or local authority by-laws;
    7. unethical behaviour;
    8. other serious improper conduct (including gross mismanagement, serious and substantial waste of the Company’s resources, or repeated breaches of administrative procedures);
    9. unsafe work-practices;
    10. any other conduct which may cause financial or non-financial loss to Terri Bell & Co or be otherwise detrimental to the interests or reputation of Terri Bell & Co, or any of its employees;
  2. the deliberate concealment of information tending to show any of the matters listed above.

Conduct that is not reportable

  1. This policy does not apply to:
    1. personal work related grievances;
    2. health and safety hazards;
    3. general employment grievances and complaints by a person about their own employment or situation.

How to speak up about reportable conduct

  1. Any person who has reasonable grounds to suspect that reportable conduct as defined in clause 9 or a breach of a law or other standard of behaviour has occurred, is encouraged to report that suspicion to his or her manager. If this is considered inappropriate, he or she should raise the concern with the Principal, by phone or email, or in writing. Any items of concern may also be raised with the CFO.
  2. All disclosures should provide specific, adequate and pertinent information with respect to, among other things, dates, places, persons, witnesses, amounts, and other relevant information, in order to allow for a reasonable investigation to be conducted.
  3. If the Whistleblower discloses his or her name in the disclosure, the person receiving the disclosure will acknowledge having received the disclosure and may initiate a follow-up meeting. However, if the disclosure is submitted on an anonymous basis, there will be no follow-up meeting regarding the disclosure and Terri Bell & Co will be unable to communicate with the Whistleblower if more information is required, or if the matter is to be referred to external parties for further investigation.
  4. All disclosures received will be dealt with on a confidential basis and Whistleblowers are encouraged to disclose their identities, to obtain the protection afforded to them at law.

Confidentiality and anonymity

  1. The Company recognises that maintaining appropriate confidentiality is crucial in ensuring that potential Whistleblowers come forward and make disclosures in an open and timely manner and without fear of reprisals being made against them.
  2. The Company will take all reasonable steps to protect the identity of the Whistleblower and will adhere to any statutory requirements in respect of the confidentiality of disclosures made. In appropriate cases, disclosure of the identity of the Whistleblower, or the allegation made by them, may be unavoidable, such as if court proceedings result from a disclosure pursuant to this policy or there is a threat to life or property or if the company has an obligation to do so.

How the company actions a Whistleblower report

  1. Once a disclosure has been received from a Whistleblower the Company will consider the most appropriate action. This might include an investigation of the alleged conduct, either by an appropriate person or a group of people, such as a committee.
  2. Any investigation in relation to a disclosure will be conducted promptly and fairly, with due regard for the nature of the allegation and the rights of the persons involved in the investigation.
  3. Any evidence gathered during an investigation, including any materials, documents or records, must be held by the investigator.
  4. During the investigation, the investigator will have access to all of the relevant materials, documents, and records. The directors, officers, employees and agents of the Company must cooperate fully with the investigator.
  5. Following the investigation, a final report will issue and appropriate action taken where applicable.

Support and protection of an eligible person following a report When the policy will operate

  1. This policy protects the Whistleblower against any reprisals, provided that the Whistleblower identifies himself or herself to the Company, and the disclosure is:
    1. reportable conduct under clause 9 of this policy;
    2. submitted in good faith and without any malice or intentionally false allegations;
    3. based on the Whistleblower’s reasonable belief that the alleged conduct, or issue related to the alleged conduct constitutes, or may constitute, a material breach of a law or other standard of behaviour; and
    4. does not result in a personal gain or advantage for the Whistleblower.

No reprisals

  1. The Company will not take any adverse action against a Whistleblower because they have made a disclosure, which meet the above-mentioned conditions, unless the Whistleblower is a participant in the prohibited activities with respect to which the complaint is made.
  2. If the Whistleblower was involved in the conduct, which was the subject of the disclosure, the fact that the Whistleblower has made the disclosure may be taken into account in determining the severity of the disciplinary measures, if any, that may eventually be taken against such Whistleblower.
  3. Any reprisals against a Whistleblower are a serious breach of this policy and may result in disciplinary action, including dismissal. This protection applies to anyone providing information related to an investigation pursuant to this policy.
  4. While it is the right of the Whistleblower to remain anonymous, if the Whistleblower does not identify themselves and requires complete anonymity, it will be hard for the Company to protect them.

Communications to the Whistleblower

  1. The Company will ensure that, provided the disclosure was not made anonymously, the Whistleblower is kept informed of the outcomes of the investigation of his or her allegations, subject to the considerations of privacy of those against whom allegations are made.

Review of policy

  1. The Company will periodically review this policy and update as required.

Further information and advice

  1. For further information, refer to other related policies or contact Terri Bell.
Parent Policy  
Associated Documents/Procedures  
Legislation mandating compliance Corporations Act 2001 (Cth) Taxation Administration Act 1953 (Cth)
Category Human Resources
Approval Managing Principal
Date Effective 11.9.2020
Review Date 11.9.2021
Version 1.0