Whistleblower

Whistleblower Protection Policy

1.1 Objectives

True Wealth Financial (TWF) is dedicated to fostering a culture of corporate compliance and ethical conduct. We have devised this Whistleblower Protection Policy in accordance with section 1317AI of the Corporations Act. This policy outlines the protections extended to Eligible Whistleblowers and delineates the actions TWF Group will take to prevent any adverse consequences following a Protected Disclosure. Throughout this policy, the term ‘TWF Group’ refers to us in various forms such as ‘we,’ ‘us,’ or ‘our.’

1.2 Policy Applicability

This policy applies to all Eligible Whistleblowers. Additionally, we may, on a case-by-case basis, consider disclosures that meet the ‘Protected Disclosure’ criteria within this policy from the following groups, even if they are not Eligible Whistleblowers:

  • External organizations not affiliated with the TWF Group
  • Members of the general public

 

1.3 Relevant Laws, Regulations, and Industry Standards

This Policy draws upon aspects of various laws, regulations, and Industry Standards, including:

  • Treasury Laws Amendment (Enhancing Whistleblower Protections) Act 2019 (Cth)
  • The Corporations Act 2001 (Cth) (‘the Act’) & the Corporations Regulations
  • AS 8000 -2003 – Corporate governance – good governance principles
  • AS 8004 -2003 – Whistleblower protection programs for entities

 

1.4 Protections for Eligible Whistleblowers

We commit to safeguarding Eligible Whistleblowers under this Policy and ensuring they do not face any repercussions for making a Protected Disclosure. Specifically:

  • We will not impose civil, criminal, or administrative liability on an Eligible Whistleblower concerning a Protected Disclosure.

  • We will not enforce any contractual obligations related to the Protected Disclosure, such as confidentiality clauses in employment agreements.

The Whistleblower Protection Officer (WPO) will collaborate with relevant TWF Group managers, employees, or officers to prevent the Eligible Whistleblower from experiencing:

  • Dismissal
  • Injury
  • Detrimental alterations to their position or duties
  • Discrimination compared to other employees
  • Harassment or intimidation
  • Harm, including psychological harm or bullying
  • Damage to their property

 

Should an Eligible Whistleblower report suffering adverse consequences due to a Protected Disclosure, this information will be treated as a new disclosure and investigated accordingly.

1.5 Personal Work-Related Grievances

The WPO and chair of the GARCC may determine that a disclosure made by an Eligible Whistleblower pertains to a personal work-related grievance rather than a Protected Disclosure. In such cases, a Whistleblower Investigation Committee (WIC) will not be convened, and the individual will not be entitled to the protections outlined in this Policy. The matter will be referred to the TWF Head of Human Resources, who will manage it following relevant policies. A disclosure constitutes a personal work-related grievance if it involves a grievance related to the discloser’s employment with the TWF Group, has personal implications for the discloser, and does not significantly affect the TWF Group, fitting outside the definition of a Protected Disclosure. Before making a disclosure, individuals should consider whether it constitutes a personal work-related grievance.

1.6 Making a Protected Disclosure

An Eligible Whistleblower can make a disclosure by:

In each case, the disclosure will be shared with the WPO, who will collaborate with the chair of the GARCC to determine its status. If the GARCC chair is involved, the matter will be referred to the Chairman of the Board of Directors. If the WPO is involved, the matter will be referred to the Senior Corporate Counsel. Subsequent references to the GARCC chair and the WPO should be interpreted accordingly. If the WPO and GARCC chair deem a disclosure not to be a Protected Disclosure, they may categorize it as a personal work-related grievance. In such instances, the disclosure will be shared with the TWF Head of Human Resources, who will manage it following relevant procedures.

1.7 Investigation of Protected Disclosures

Upon confirming that a disclosure is a Protected Disclosure, a WIC will be formed to investigate the matter. The investigation will be exclusively managed by the WIC. The composition of the WIC will depend on the nature of the conduct to be investigated. For each WIC, the WPO and GARCC chair will select a third member, considering the specifics of the disclosure. This may entail selecting a member of the Executive Team, a business unit head, their delegates, or an external party, if deemed appropriate. A minimum of three (3) members will investigate each matter. The WIC will strive to notify the Eligible Whistleblower within 10 Business Days of formation, providing an update on the proposed action. Recommendations from the WIC