Purpose

This policy exists to encourage the reporting of wrongdoing and protect individuals who disclose suspected unethical, illegal or improper conduct.

It upholds CatholicCare’s mission to share in the healing ministry of Jesus by providing professional community services to enhance the wellbeing of individuals and families and embodies our values: Be Kind | Create Connection | Work Together.

This policy supports clause 3.5 of the Constitution (2024) requiring all programs and procedures to be faithful to the Gospel and reflect human dignity.

Scope

This policy applies to all employees, volunteers, contractors, and Board members.

Policy Statement

CatholicCare fosters a speak-up culture that encourages disclosure of misconduct and protects those who report it.

We commit to:

  • Providing safe and confidential channels for reporting;
  • Protecting whistleblowers from detriment, discrimination or reprisal;
  • Investigating reports fairly and promptly;
  • Acting on substantiated findings to improve systems and culture;
  • Ensuring all actions align with Catholic values, natural justice and legislative requirements.

Legislative & Standards Alignment

Part 9.4AAA — Whistleblower protections and confidentiality obligations.

Provides for protected disclosures of corrupt conduct and maladministration.

Standard 2.3 Accountability and Quality Systems — requires transparent and ethical governance.

Governance and Operational Management — requires systems to prevent and respond to fraud and misconduct.

Standard 6 Governance and Accountability — integrity in decision-making.

Standards 1 & 9 — committed leadership, governance and continuous improvement in safeguarding culture.

Standard 1 Leadership and Culture — embedding a safe, transparent and accountable reporting environment.

Principle 5 Performance and Accountability — upholding transparency; Principle 8 Organisational Culture — supporting speak-up culture.

Clause 10 Improvement — systematic handling of non-conformities and whistleblower feedback.

Responsibilities

Approves policy; monitors systemic issues and oversight of whistleblower reports.

Ensures an independent, confidential process for reporting and investigation; reports serious matters to the Board and Member as required.

Receives, triages and oversees investigations and protective actions.

Foster a speak-up culture and escalate concerns appropriately.

Report suspected misconduct in good faith and cooperate with investigations.

Procedures & Implementation

Reporting Channels

  • Email, phone or in-person to the WPO, a responsible person or another worker.
  • Anonymous reports accepted through dedicated confidential email.
  • Disclosures may also be made to the Board Chair where the CEO is implicated.

Eligible Matters

  • Fraudulent activity or improper conduct; unethical, dishonest or illegal conduct; corruption, theft, bribery, safety breaches, abuse of authority, breaches of relevant Acts, concealment of wrongdoing, unsafe work practices.

Assessment and Investigation

  • WPO acknowledges receipt within five (5) business days.
  • Preliminary assessment determines eligibility under this policy.
  • Independent investigator appointed if conflict exists.
  • Findings and recommendations reported to CEO and Board.

Confidentiality and Record Keeping

  • Identity protected unless law requires disclosure.
  • Records kept securely in restricted quality system files in Carlo.

Protection and Support

  • Protection from punishment, unfair treatment, threats and victimisation
  • No retaliation or disadvantage for genuine disclosures.
  • Protective measures may include relocation, modified duties, counselling, or paid leave.
  • Protection extends to older people, their families and carers

Reporting and Review

  • Annual summary of whistleblower matters reported to Board, Risk & Compliance Committee with de-identified data.
  • Learnings inform continuous improvement and training plans.

Training & Communication

  • Policy communicated via Blink and staff induction.
  • Annual refresher training on ethical conduct, fraud awareness and reporting channels.
  • Leadership development modules reinforce speak-up culture and non-retaliation obligations.

Monitoring, Evaluation, & Continuous Improvement

  • Trends and themes analysed through the Continuous Improvement Register.
  • Findings inform risk register updates and policy reviews.
  • Effectiveness evaluated annually as part of QMS audit cycle.

Breaches & Non-Compliance

  • Retaliation against a whistleblower or failure to act on substantiated misconduct is a serious breach (a breach that may result in the organisation exceeding its risk appetite) that may lead to disciplinary action, termination, or referral to authorities.
  • Malicious or vexatious reports made in bad faith may also result in disciplinary action.
  • Serious breaches (breaches that may result in the organisation exceeding its risk appetite) must be escalated to the CEO as per procedure 02 LG 1 Governance Framework.

Related Documents

  • 01 QM 3 – Accreditation against external standards
  • 01 QM 4 – Reporting Framework
  • 01 QM 7 – Audit and Review Framework
  • 02 LG 1 – Governance Framework
  • 02 LG 4 – Accountability and Delegations
  • 02 LG 5 – Code of Conduct
  • 03 PR 3 – Managing organisational and Operational Risk
  • 08 MR 2 – Client feedback including Complaints

Definitions

A person who reports misconduct in good faith under this policy.

Behaviour that is dishonest, illegal, unethical or contrary to CatholicCare policy or the law.

Any actual or threatened retaliation, harassment, discrimination or injury for making a disclosure.

Senior officer responsible for managing disclosures and ensuring protection measures.

Worker, staff member, volunteer, student on placement

Policy version 2 – Updated 20/01/2026