WHISTLEBLOWER POLICY FOR Willow House Community Support Ltd

1. Purpose and availability of policy

(a) Willow House Community Support Ltd is committed to a culture of good commercial
practice and highly ethical behaviour.

(b) This policy deals with issues relating to those employees (or others) who wish to raise
issues about whether Willow House Community Support Ltd or its employees have
complied with applicable laws and other standards of behaviour (such as Willow House
Community Support Ltd’s policies or codes of conduct).

2. Application

(a) This policy applies to all current and former employees, volunteers and suppliers of Willow
House Community Support Ltd. Other persons (such as third-party contractors, customers,
relatives, dependants or dependants of spouses of any employee) may use the procedures
in this policy.

(b) In this policy, the people this policy applies to are referred to as an “eligible person”
(Eligible Person).

3. Objectives

The objectives of this policy are to:

(a) encourage every Eligible Person to disclose any malpractice, misconduct or conflicts of
interest of which they become aware;

(b) provide protection for every Eligible Person who disclose allegations of malpractice,
misconduct or conflicts of interest; and

4. Policy

4.1 Whistleblower protection

(a) This policy is designed to give guidance so that honesty and integrity are
maintained at all times at Willow House Community Support Ltd.
(b) 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).
(c) 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.

4.2 Reportable conduct

(a) 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.
(b) Examples of things that may be considered misconduct or an improper state of
affair or circumstances include:
(i) dishonesty;
(ii) fraud;
(iii) corruption;
(iv) illegal activities (including theft, drug sale/use, violence, threatened violence,
or criminal damage against Willow House Community Support Ltd
assets/property);
(v) discrimination, vilification, sexual harassment, harassment, bullying and
victimisation;
(vi) acts or omissions in breach of commonwealth or state legislation or local
authority by-laws;
(vii) unethical behaviour;
(viii) other serious improper conduct (including gross mismanagement, serious
and substantial waste of Willow House Community Support Ltd resources,
or repeated breaches of administrative procedures);
(ix) unsafe work-practices;
(x) any other conduct which may cause financial or non-financial loss to Willow
House Community Support Ltd or be otherwise detrimental to the interests
or reputation of Willow House Community Support Ltd, or any of its
employees; or
(xi) the deliberate concealment of information tending to show any of the matters
listed above.

4.3 Conduct that is not reportable

This policy does not apply to:

(a) personal work-related grievances;
(b) health and safety hazards; or
(c) general employment grievances and complaints by a person about their own
employment or situation.

5. How to speak up about reportable conduct

(a) Any person who has reasonable grounds to suspect that reportable conduct as defined in
clause 4.2 or a breach of a law or other standard of behaviour has occurred, is encouraged
to report that suspicion to that person’s manager. If this is considered inappropriate, that
person should raise the concern with The CEO or
COO(admin@willowcommunitysupport.org), by phone or email, or in writing. Any items of
concern may also be raised with The CEO or COO.

(b) 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.

(c) If the Whistleblower’s name disclosed 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 Willow House Community Support Ltd 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.

(d) 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.

6. Confidentiality and anonymity

(a) Willow House Community Support Ltd 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.

(b) Willow House Community Support Ltd 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.

7. How the company actions a Whistleblower report

(a) Once a disclosure has been received from a Whistleblower, Willow House Community
Support Ltd 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

(b) 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.

(c) Any evidence gathered during an investigation, including any materials, documents or
records, must be held by the investigator, and held securely.

(d) During the investigation, the investigator will have access to all of the relevant materials,
documents, and records. The directors, officers, employees and agents of Willow House
Community Support Ltd must cooperate fully with the investigator.

(e) Following the investigation, a final report will issue and appropriate action taken where
applicable.

8. Support and protection of an Eligible Person following a report

8.1 When the policy will operate

This policy protects the Whistleblower against any reprisals, provided that the
Whistleblower identifies himself or herself to Willow House Community Support Ltd, and
the disclosure is:

(a) reportable conduct under clause 4.2 of this policy;

(b) submitted in good faith and without any malice or intentionally false allegations;

(c) 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

(d) does not result in a personal gain or advantage for the Whistleblower.

8.2 No reprisals

(a) 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.

(b) 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.

(c) 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.

(d) 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 Willow House Community Support Ltd to protect them.

9. Communications to the Whistleblower

Willow House Community Support Ltd will ensure that, provided the disclosure was not made
anonymously, the Whistleblower is kept informed of the outcomes of the investigation of the
allegations, subject to the considerations of privacy of those against whom allegations are made.

10. Review of policy

Willow House Community Support Ltd will periodically review this policy and update as required.

11. Further information and advice

For further information, refer to other related policies or contact The CEO or COO
(admin@willowcommunitysupport.org).

WHISTLEBLOWER POLICY