Whistleblower Policy

RESPONSIBILITY TO SPEAK UP

Employees and those we do business with have a responsibility to report concerns if they suspect or become aware of misconduct that is a Reportable Matter.

Reportable Matters involve any actual or suspected misconduct or an improper state of affairs in relation to AHL or a related body corporate or an officer or employee of AHL.
You must have reasonable grounds for reporting such conduct but you should speak up even if you are unsure if something is a Reportable Matter.
Reportable Matters do not generally include personal work-related grievances.

Examples of Reportable Matters include

Fraud, bribery or corrupt activities (e.g. theft; misappropriation; insider trading; market manipulation; and corrupt practices including giving or receiving bribes or other improper benefits).
Illegal or criminal conduct (e.g. drugs; violence; or other breaches of law or regulatory requirements).
Unethical conduct or breaches of AHL’s policies or Code of Conduct (e.g. conflicts of interest; illegal, deceptive or anti-competitive practices; bullying, harassment and non-adherence to internal compliance policies; and non-compliance with legislation including Human Rights legislation).
Unsafe work practices, environmental damage or substantial wasting of AHL’s resources (e.g. practices that endanger the safety of employees/ the public, unsafe or unhealthy working practices, non-compliance with required environmental laws and practices).
Conduct that may cause financial loss or damage in any way to AHL’s reputation or be otherwise detrimental to AHL’s interest (e.g.falsification or destruction of business or financial records;misrepresentation or suppression of financial information; non-adherence to internal financial reporting policy/controls).
Actual or threatened harassment, discrimination, victimisation, bullying or any other type of detrimental action (e.g. statements, conduct or actions involving terminating, disciplining, suspending, harassing or discriminating against an individual reporting a concern on reasonable grounds in accordance with this policy).
Abuse of authority (e.g. use of office for personal gain; coercion of another employee; exceeding financial delegations).

Fraud, bribery or corrupt activities
Illegal or criminal conduct (e.g. theft, drugs, violence, or other breaches of law or regulatory requirements)
Unethical conduct or breaches of AHL’s polices or Code of Conduct
Unsafe work practices, environmental damage or substantial wasting of AHL’s resources
Conduct that may cause financial loss or damage in any way to AHL’s reputation or be otherwise detrimental to AHL’s interest
Actual or threatened harassment, discrimination, victimisation or bullyingor any other type of detrimental action
Abuse of authority.

SPEAK UP

There are several channels for making a report if you become aware of any issue or behaviour which you consider to be a Reportable Matter.

AHL encourages reports of Reportable Matters to be made to any of the following recipients:

- Whistleblower Protection Officer
- Relevant supervisor, senior manager or officer
- Chair of the Audit and Risk Committee
- Any member of the Board
- Company Secretary

WHISTLEBLOWER PROTECTION OFFICERS

Annie Rafferty
GM - People & Culture
Phone: +61 8 8243 9890

BY EMAIL

SpeakUp@adrad.com.au

(or via the online report below)

If you have additional documents, material or information please email them to us.

BY POST

Reports may also be posted to
Adrad Holdings Limited
26 Howards Road, Beverley SA 5009
(marked Private & Confidential and to the attention of one of the Whistleblower Protection Officers).

ANONYMOUS REPORTS

AHL also appreciates that speaking up can be difficult. Anonymous reports can be made by sending an anonymous email using a temporary or disposable email address available from the internet.

EXTERNAL RECIPIENTS

Nothing in AHL’s Whistleblower Policy (including anonymous reporting) should be taken in any way as restricting someone from reporting any matter or providing any information to a regulator (e.g. ASIC, APRA or a prescribed Commonwealth authority).

Read our policy

AHL’s Whistleblower Policy should encourage and support people to feel confident to speak up safely and securely if they become aware of wrong-doing or illegal or improper conduct within the organization. The Policy (download here) forms part of our Corporate Governance Plan (specifically Schedule 10) approved by the Board on 30 June 2022.

To view our full Corporate Governance Plan, please download the PDF.

อ่านนโยบายการแจ้งเบาะแสเป็นภาษาไทย คลิ๊กตรงนี้

Whistleblower report

CONFIDENTIALITY AND ANONYMITY

All matters reported will be taken seriously. Disclosures will be treated confidentially and shared only to the extent necessary to allow an investigation or to determine what action is appropriate. Your identity can be kept confidential. While there are some circumstances where it may need to be disclosed to authorities we would discuss this with you before that occurred. If you decide to provide information completely anonymously, it could limit our ability to fully investigate and address the matters you raise. It may also mean you wouldn’t be able to assist with any questions or receive feedback or updates on the matters reported.

Who is the complaint about?

Names of the persons who are the subject of the complaint (if known)

Positions of the persons who are the subject of the complaint (if known)

Team/Section (if known)

Names of AHL business entities who are the subject of the complaint (if known)

Geographical location / address of AHL business entities (if known)

Summary of complaint or report

Describe the conduct you wish to register a complaint or report about

When did this conduct occur?

When did you become aware of this conduct?

Where did this conduct occur?

How did you become aware of this conduct?

Have you reported this conduct elsewhere? If Yes:

Were there other witnesses to the incident? If Yes:

About you (optional)

Your Name

Your Email (preferred)

Your Phone (preferred)

Your Position

Team/Section

AHL business entity

Address of AHL business entity

Consent (optional)

Do you have any objections to the disclosure of your identity for the purposes of the investigation?

Thank you for taking the time to complete this form.