CBM Australia is committed to a culture of integrity, transparency and accountability.
Whistleblowing, and whistleblower protections, create an important pathway for both external community and internal workplace participant reporting of concerns and suspicion of illegal or dishonest activity relating to CBM Australia’s work.
CBM Australia requires the reporting of known or reasonably suspected misconduct where it is Reportable Conduct.
Reportable Conduct is conduct that a person has reasonable grounds to suspect is misconduct, wrongdoing, or an improper state of affairs, relating to CBM Australia, its partners or any related entities.
Reportable Conduct includes conduct that is reasonably believed to be
An employee’s personal work related grievance is not Reportable Conduct. Further relevant internal Standards and Procedures, including grievance procedures, are available to employees.
A whistleblower is generally a person associated with CBM Australia who reports known or reasonably suspected misconduct. A whistleblower may be a current or former workplace participant, or their family member, or a current or former program partner participant. Workplace participants includes anyone engaging in work for CBM Australia. This includes full time, part time and casual employees, contractors and volunteers.
Reportable Conduct should be reported as soon as the workplace or program partner participant becomes aware of the conduct. Report should be made in the country most relevant to the conduct.
CBM Australia provides 3 mechanisms for whistleblowing:
For conduct outside Australia, the CBM International whistleblowing report system is available here.
In Australia, Reportable Conduct disclosure can be reported anonymously. All information disclosed in any reporting, including identity (if provided), will remain confidential to the extent required by law.
Where necessary, CBM Australia may disclose a whistleblower’s identity to authorities (for example, the Australian Federal Police). In some circumstances, information that might lead to personal identification may be disclosed to an investigator where it is reasonably necessary for assessing and responding to the report made. All reasonable steps will be taken to reduce the risk of personal identification.
CBM Australia’s People and Culture Director is also the sole recipient of disclosure through CBM Australia’s email and online report system. If the People and Culture Director is implicated in the disclosure, report by mail or phone can be made to the Chief Executive Officer. If the CEO is implicated in the disclosure, report by mail can be made to the CBM Australia Board Chair.
Any person who knowingly makes a false report of Reportable Conduct, or who otherwise fails to act honestly with reasonable belief in respect to the report, may be subject to disciplinary action, including dismissal (in the case of employees).
Reportable Conduct disclosure can be made to a member of parliament or a journalist under certain circumstances, being a ‘public interest disclosure’ or an ‘emergency disclosure’, where a disclosure has already been made to a Commonwealth Authority, and at least 90 days have passed, or where there are reasonable grounds to believe that the Reportable Conduct involves substantial and imminent danger to health, safety or environment. A whistleblower should seek their own advice in this regard.
A whistleblower disclosing to CBM Australia will be notified when their report has been received, and should not attempt to investigate any Reportable Conduct themselves.
CBM Australia will assess all reports of Reportable Conduct to determine whether they have been made on reasonable grounds.
CBM Australia will make a preliminary assessment of a report to determine whether the conduct indicated warrants an investigation. CBM Australia may then conduct an internal investigation or appoint an external investigator. CBM Australia may also take other steps, including seeking additional information, to properly assess the situation and make appropriate response.
A whistleblower disclosing to CBM Australia will receive feedback on the outcome of any assessment or investigations, subject to privacy and confidentiality restrictions.
CBM Australia will decide what steps should be taken to address any verified misconduct or improper state of affairs or circumstances, always ensuring steps are undertaken in a fair manner for those mentioned in reporting made.
CBM Australia is responsible for protecting a whistleblower disclosing to CBM Australia against detriment or disadvantage as a result of making report.
CBM Australia is committed to protecting and supporting whistleblowers who report Reportable Conduct.
CBM Australia will take all reasonable precautions to ensure that a whistleblower (and their colleagues and relatives, as relevant) is not subject to detriment. To the extent that it is reasonable and practical to do so, CBM Australia will monitor and manage the behaviour of any people involved in the report made. CBM Australia will further take all reasonable precautions to ensure that a whistleblower is not harmed, injured, intimidated, harassed, bullied or victimised by any CBM Australia employee, volunteer, contractor, supplier or consultant. CBM Australia will consider any reasonable request for additional protections (for example, employee leave of absence during an investigation).
Certain protections may also apply at law to protect a whistleblower against civil or criminal litigation or disciplinary proceedings. CBM Australia cannot give individual advice in this respect.