Whistle-blower Policy for KIDS4KIDS FOUNDATION CHARITY

1. Purpose and availability of policy
(a) KIDS4KIDS FOUNDATION CHARITY 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 KIDS4KIDS FOUNDATION CHARITY or its employees have complied with applicable laws and other standards of behaviour (such as KIDS4KIDS FOUNDATION CHARITY’s policies or codes of conduct).
(c) This policy is available on www.kids4kidsfoundation.org.

2. Application
(a) This policy applies to all current and former employees, volunteers and suppliers of KIDS4KIDS FOUNDATION CHARITY. Other persons (such as third-party contractors, customers relatives, dependents or dependents 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
(c) indicate when such disclosures will be investigated.

4. Policy
4.1. Whistle-blower protection
(a) This policy is designed to give guidance so that honesty and integrity are maintained at all times at KIDS4KIDS FOUNDATION CHARITY.
(b) To the maximum extent practicable, a person who genuinely discloses an allegation or concern about compliance with laws or other standards of behaviour (Whistle-blower) 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 Whistle-blower 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 reasonable conduct will also be protected. Every effort will be made to protect
the anonymity of the Whistle-blower. however, there may be situations where anonymity cannot be guaranteed. In such situations, the Whistle-blower will be informed
4.2. Reportable conduct
(a) Reportable conduct that can be the subjected of a protected Whistle-blower 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 KIDS4KIDS FOUNDATION CHARITY assets/property):
(v) discrimination, vilification, sexual harassment, harassment, bullying and victimization;
(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 KIDS4KIDS FOUNDATION CHARITY resources. or repeated breaches of administrative procedures);
(ix) unsafe work-practices;
(x) any other conduct which may cause financial or non-financial loss to KIDS4KIDS FOUNDATION CHARITY or be otherwise detrimental to the interests or reputation of KIDS4KIDS FOUNDATION CHARITY. 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 Company Directors(admin@kids4kidsfoundation.org.au), by phone or email, or in writing. Any items of concern may also be raised with Company Directors.
(b) All disclosures should provide specific, adequate and pertinent information with respect to among other things, dates, places persons witness amounts, and other relevant information, in order to allow for a reasonable investigation to be conducted.
(c) If the Whistle-blower’s name disc lose d in the disclosure, the person receiving the dis closure 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 KIDS4KIDS FOUNDATION CHARITY will be unable to communicate with the Whistle-blower 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 Whistle-blowers are encouraged to disclosure their identities, to obtain the protection afforded to them at law.

6. Confidentiality and anonymity
(a) KIDS4KIDS FOUNDATION CHARITY recognizes that maintaining appropriate confidentiality is crucial in ensuring that potential Whistle-blowers come forward and make disclosures in an open and timely manner and without fear of reprisals being made against them.
(b) KIDS4KIDS FOUNDATION CHARITY will take all reasonable steps to protect the identity of the Whistle-blower and will adhere to any statutory requirements in respect of the confidentiality of disclosures made in appropriate cases, disclosure of the identity of the Whistle-blower, 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 Whistle-blower report
(a) Once a disclosure has been received from a Whistle-blower, KIDS4KIDS FOUNDATION CHARITY 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 KIDS4KIDS FOUNDATION CHARITY 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 Whistle-blower against any reprisals, provided that the Whistle-blower identifies himself or herself to KIDS4KIDS FOUNDATION CHARITY, 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 Whistle-blower 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 Whistle-blower.
8.2. No reprisals
(a) The company will not take any adverse action against a Whistle-blower because they have made a disclosure which meet the above-mentioned conditions, unless the Whistle-blower is a participant in the prohibited activities with respect to which the complaint is made.
(b) If the Whistle-blower was involved in the conduct, which was the subject of the disclosure the fact that the Whistle-blower 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 Whistle-blower.
(c) Any reprisals against a Whistle-blower 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 Whistle-blower to remain anonymous, if the Whistle-blower does not identify themselves and requires complete anonymity it will be hard for KIDS4KIDS FOUNDATION CHARITY to protect them

9. Communications to the Whistle-blower
KIDS4KIDS FOUNDATION CHARITY will ensure that, provided the disclosure was not made anonymously, the Whistle-blower 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
KIDS4KIDS FOUNDATION CHARITY will periodically review this policy and update as required.

11. Further information and advice
For further information refer to other related policies or contact Company Secretary (secretary@kids4kidsfoundation.org.au)