Whistleblower Policy

This Policy applies to:

• officers and employees of Assetinsure;
• individuals who supply services or goods to Assetinsure (paid or unpaid);
• employees of companies that supply services or goods to Assetinsure (paid or unpaid);
• officers of Assetinsure’s related companies; and
• relatives of any of the persons listed above, including their spouses, their dependants and
  their spouse’s dependants.

Eligible Whistleblowers should, and employees of Assetinsure must, make a disclosure under this policy if they reasonably suspect any serious misconduct that includes but is not limited to:

• Theft and Fraud
• Financial Irregularities
• Breach of Whistleblower Protections
• Conflicts of Interest
• Money Laundering
• Human Rights [issues/abuses]
• Bribery and Corruption
• Workplace Health and Safety

It is encouraged for a person to disclose their identity when making a whistleblower submission so that the investigation can be more fulsome with access to follow-up information. However, a disclosure may be made anonymously and still be eligible for protection. Where a report is submitted anonymously, any investigation and related enquiries will be based on the information initially provided.

What will not be considered a “protected disclosure”?

It is important to note that not all matters reported will automatically qualify under whistleblowing legislation. Reports made regarding Assetinsure will be treated seriously and in confidence but not all matters reported may meet the relevant criteria to be treated as an instance of whistleblowing.

This Policy does not apply to:

1. trivial or vexatious matters, minor oversights, mistakes or routine matters
2. personal work-related grievances (such as a staff member’s current or former employment or engagement).

If you suspect instances of suspected unethical, illegal, fraudulent or undesirable conduct by Assetinsure or its officers, employees or agents, a report should be made to the Whistleblower Hotline Service below.

Whistleblower Hotline Service [Preferred]

This Whistleblower Hotline is a dedicated confidential service managed through the Hopgood Ganim law firm to record and manage all disclosures.

You can contact the hotline by:

Calling: 1800 879 606

Email: whistleblower@hopgoodganim.com.au

Using this service provides two important advantages:

• The service operates independent of Assetinsure and the identity of the whistleblower caller will not be reported to Assetinsure
• The hotline is staffed with persons that are experts in the management of whistleblower matters.

Other available options

While you are encouraged to make reports under this Policy to the Whistleblower Hotline Service directly, you are also entitled to make a report through one of the below channels.

Where you choose to make a report to one of the options below, it is important that you state that you wish to make a report under the Assetinsure Whistleblower Policy, so that the recipient understands that the terms of the Policy need to be met.

Director or executive of Assetinsure

You may contact a director or executive manager of Assetinsure with the matter.

If you choose to make your report direct to Assetinsure, it is recommended that you contact one of the nominated Assetinsure senior members serving as Whistleblower Protection Officers of the company being:

1. Chief Executive Officer, Martin McConnell (Martin.McConnell@assetinsure.com.au),
2. Chief Risk Officer, David Southwell (David.Southwell@assetinsure.com.au),
3. Head of Human Resources, Erika Buckley (Erika.Buckley@assetinsure.com.au)

These persons can be contacted by phone using 02 9251 8055 or by emailing them directly.

Other channels

Disclosures can also be made by contacting:
a) An Australian government authority body (eg Australian Securities & Investments Commission, Australian Federal Police etc)
b) A legal practitioner for the purposes of obtaining legal advice or legal representation in relation to whistleblower rights at law
c) an auditor or a member of an audit team conducting an audit (Deloitte or Grant Thornton)
d) In some circumstances a “public interest disclosure” or “emergency disclosure” to a journalist or parliamentarian

Once a disclosure has been made, Assetinsure will undertake all reasonable steps to have the matter investigated by nominating an investigator (Nominated Investigator). The Nominated Investigator will be carefully chosen to be independent of any relevant matter. The Nominated Investigator will review the disclosure and provide feedback to the Whistleblower on the outcome (unless made anonymously). The investigation will be done in a fair, objective, and confidential manner.

1. Confidentiality – All whistleblower reports will be treated in a sensitive manner and will not disclose the Whistleblower’s identity (where the call is not made anonymously), without first obtaining their consent. A Whistleblower’s identity may however be disclosed without consent to ASIC, APRA, a member of the Australian Federal Police or to a lawyer for the purpose of obtaining legal advice or representation in connection with the operation of the whistleblower laws
2. Investigations of disclosures – All disclosures covered by this Policy will be taken seriously and handled confidentially, sensitively and fairly. Assetinsure will ensure, and will procure that the Nominated Investigator ensures, all protected disclosures are investigated as soon as reasonably practicable. Where appropriate, the Whistleblower will be kept informed as to the progress of the investigation.
3. Protection from detriment – Assetinsure will take all reasonable steps to protect whistleblowers from detrimental conduct and will take action it considers appropriate where such conduct is identified
4. No criminal or civil liability – Making a protected disclosure will not give rise to any civil, criminal or administrative liability (including disciplinary action) on the part of the Whistleblower. Furthermore, making the disclosure and its content is not admissible against the Whistleblower in civil, criminal or administrative proceedings. Intentionally made false disclosures could result in Assetinsure pursuing legal action or other consequences.
5. Protection of records – Assetinsure will take reasonable precautions to ensure all information, documents, records and reports relating to the investigation of a disclosure will be confidentially stored and retained in an appropriate and secure manner and permit access by authorised persons only.