Purpose

The purpose of this Policy is to:

1. protect and support those who make disclosures of misconduct in relation to Roundabout Canberra; 
2. provide a reporting and investigation process for such disclosures; and
3. help deter potential misconduct.

The guiding principle underpinning this Policy is that Roundabout Canberra takes improper conduct very seriously. It is important that staff and volunteers feel that they can safely report any such misconduct without fear of repercussions. 

Overview

Roundabout Canberra is committed to the highest standards of legal, ethical, and moral behaviour. Roundabout Canberra is guided by a Code of Conduct which aims to develop a culture of respect, integrity, care, and diligence. 

A key part of supporting ethical standards is enabling people to speak up about unethical or unlawful conduct. Roundabout Canberra will not tolerate any retaliatory action or threats of retaliatory action against a person reporting such misconduct (referred to as a whistleblower) or any person involved in the investigation process. 

Disciplinary action, up to and including termination of employment or engagement, may be imposed on anyone shown to have caused detriment to a person because they want to, or have, reported misconduct.

Scope

This Policy applies to everyone who works for Roundabout Canberra, including:

1. all current and former employees; 
2. any person who works or has worked for Roundabout Canberra under a contract, including a consultant, contractor, subcontractor, employee of a contractor or subcontractor or employee of a labour hire company who has been assigned to work at Roundabout Canberra; and
3. all current and former apprentices, trainees, students gaining work experience and volunteers
4.  a relative, dependent, or spouse of an individual identified in (a) to (c) above.

Policy

Roundabout Canberra (hereby Roundabout) requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the Roundabout Canberra, it is expected that we practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations. Roundabout Canberra is committed to supporting and respect anyone who acts as a whistle-blower to draw attention to suspected inappropriate, corrupt or illegal conduct or behaviour.

Reporting Responsibility 

This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that Roundabout Canberra can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees and volunteers to report concerns about violations of Roundabout Canberra’s Code of Conduct or suspected violations of law or regulations that govern Roundabout Canberra’s operations.

Reportable Concerns

Roundabout Canberra encourages any individual identified in (a) to (d) to report misconduct and/or reasonable suspicions that any of the following have taken place, are taking place, an intent exists to carry any of the following out in the future, or that any of the following qualified disclosures have been concealed:

• fraud, that is, a deliberate deception in order to secure personal gain or cause disadvantage;
• corruption, that is, the improper use of influence or position and/or improper use of information by commission or omission;
• criminal offences by Roundabout Canberra staff or third parties;
• conduct endangering health and safety or causing damage to the environment;
• undeclared conflicts of interest, including those relating to outside business interests, relationships, improper payments and donations;
• sexual exploitation, victimisation, harassment or abuse;
• unethical or other serious improper conduct, including such conduct that is in breach of Roundabout Canberra’s policies and procedures.

To qualify for protection, the whistleblower must have reasonable grounds to suspect that the information they will disclose indicates misconduct.

To qualify for protection, a whistleblower must also make their disclosure to an eligible recipient:

• The Australian Securities and Investment Commission (ASIC)
• The Australian Prudential Regulatory Authority (APRA)
• A Commonwealth body nominated for this purpose in the Regulations (not the ACNC)
• A legal practitioner, if someone is seeking legal advice about whether the protections will apply to them
• The CEO or a Board Member of Roundabout Canberra 
• An auditor or member of the audit team for Roundabout Canberra
• A person that Roundabout Canberra has authorised to receive a disclosure (‘nominated person’)

Reporting Procedure

Roundabout Canberra has an open door policy and suggests that team members share their questions, concerns, suggestions or complaints with their Manager or the CEO in the first instance. If you are not comfortable speaking with your Manager or the CEO or you are not satisfied with their response, you are encouraged to speak with Roundabout Canberra’s nominated person, Amy Critchley (Board Chair). All Roundabout Canberra Managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the Roundabout Canberra’s nominated person, who has the responsibility to investigate all reported complaints. Employees with concerns or complaints may also submit their concerns in writing directly to their Manager or the CEO.

Handling of Reported Violations

Roundabout Canberra’s nominated person will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

No Retaliation

It is contrary to the values of Roundabout Canberra for anyone to retaliate against any board member, officer, employee or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of Roundabout Canberra. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

Acting in Good Faith

Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Nominated Person

Roundabout Canberra’s nominated person is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The nominated person will advise the CEO and the Board of Directors of all complaints and their resolution and will report at least annually to the on compliance activity relating to accounting or alleged financial improprieties. Roundabout Canberra’s nominated person is Amy Critchley, Board Chair.

Note: The nominated person may be a board member, the Executive Director, or a third party designated by the organization to receive, investigate and respond to complaints.

Personal work-related grievances

Disclosures that relate solely to personal work-related grievances, and do not relate to detriment or threat of detriment to the person reporting misconduct, are not covered by this Policy.

Legislative Framework

Additional information can be found in the Corporations Act 2001 (Cth) (Corporations Act) and the Taxation Administration Act 1953 (Cth), both of which contain protections for whistleblowers.