Whistleblower Policy

As at 1st August 2020


Every stakeholder of Fishburners should have the chance to report legitimate wrongdoing  via a safe and confidential process. 

  1. SCOPE

This Policy applies to all of Fishburners services regardless of entity name or type. It encompasses all Directors and personnel including executives, managers, staff, members, contractors, consultants, volunteers and interns. 


The Board and Management of Fishburners strongly believe that the responsible use of Company resources and the safety, security, physical and mental health and wellbeing of our staff is an essential part of how we undertake our business. Fishburners is committed to providing and maintaining a professional, safe and healthy working environment for people working on behalf of Fishburners. 

With our whistleblowing policy, we aim to ensure that:

  • The identity of the person making the disclosure remains confidential according to their wishes
  • We will investigate every report of misconduct. At the end of the investigation, we will document the results and provide feedback when appropriate

Fishburners wants to hear from you if you witness or know about any behaviour that is:

  • Fraudulent;
  • Illegal;
  • Corrupt;
  • Dishonest;
  • Unethical;
  • Violates the law or any legal code;
  • Is creating an unsafe environment;
  • Breaches any of our company’s policies;
  • Discriminatory
  • Harassment and/or bullying of any kind;
  • Any conduct which is detrimental to Fishburners and could cause financial or non-financial loss;


A Whistleblower must provide information to assist any inquiry/investigation of the wrongdoing disclosed.

Making a disclosure may not protect the Whistleblower from the consequences flowing from involvement in the wrongdoing itself. A person’s liability for their own conduct is not affected by their report of that conduct under this policy. However active cooperation in the investigation, an admission and remorse may be taken into account when considering disciplinary or other action.

Even though a Whistleblower may be implicated in the wrongdoing they must not be subjected to any actual or threatened retaliatory action or victimisation in reprisal for making a report under this policy.

Protection of Whistleblowers and Confidentiality

If you wish to remain anonymous during the investigation of the incident, please let us know. Fishburners and the Board respects and protects your identity if you choose to make an anonymous report. At any given time you can identify yourself, but this is your choice and at no point do you need to do this or will you be forced to provide your identity.

Protection is available to Whistleblowers who disclose wrongdoing that is made with reasonable grounds to believe it is true. To ensure that all employees are treated fairly and that resources are not wasted, protection is not available where the disclosure is: 

  • Trivial or vexatious in nature with no substance. This will be treated in the same manner as a false report and may itself constitute wrongdoing. 
  • Unsubstantiated allegations which are found to have been made maliciously, or knowingly to be false. These will be viewed seriously and may be subject to disciplinary action that could include dismissal, termination of service or cessation of a service or client relationship. 

Whistleblower Protection Officer 

A Whistleblower Protection Officer may be appointed if a Whistleblower wishes. This is an officer, senior manager or employee to support and provide protection to the Whistleblower according to this policy. The Whistleblower Protection Officer must have a direct reporting line to an Executive Leader from an area of the organisation that is independent of line management in the area that is the subject of the report of wrongdoing. The Whistleblower Protection Officer will provide mentoring and other support deemed necessary by the Whistleblower Protection Officer and be responsible for keeping the Whistleblower informed of the progress and outcomes of the inquiry/investigation subject to considerations of privacy of those against whom a disclosure has been made. 

Whistleblower Governance Officers 

A Whistleblower Governance Officer includes those people named under item 6: Reporting a Disclosure of this policy and as such are responsible for receiving whistleblower disclosures of wrongdoing and oversighting resolution. 


Fishburners  will investigate all matters reported under this policy as soon as practicable after the matter has been reported. 

The investigation will be conducted in an objective and fair manner, and as is reasonable and appropriate having regard to the nature of the disclosure and the circumstances. Where a report is submitted anonymously, Fishburners will conduct the investigation and its enquiries based on the information provided to it. However, anonymity can sometimes prevent Fishburners from taking the issue further if it is not able to obtain further information from the source of the report.

The Investigator may second the expertise of other officers in Fishburners to assist in the investigation and may seek the advice of internal or external experts as required.


Internal Whistleblowers (current or former Directors, employees, members, volunteers, interns, contractors or consultants) are encouraged to report their concerns to their supervisor or their supervisors’ manager to seek an immediate response. Where the internal Whistleblower believes this is not appropriate, then an alternative reporting mechanism is available (see below).

External whistleblowers (other people with a relationship with Fishburners) are encouraged to report their concerns to the CEO or Chair of The Board.

Alternative reporting

Alternative reporting to normal channels are available where:

  • The normal reporting channel is considered inappropriate to the circumstances;
  • Fishburners line management was notified but failed to deal with it; or
  • The person or organisation disclosing wrongdoing is concerned about possible retaliation.

In any of these circumstances, an internal Whistleblower may provide the report of wrongdoing directly to:

  • The Chair of Fishburners


  • A person or entity who is eligible to receive the disclosure under the Corporations Act 2001

If an employee or eligible person would like to make a report, they have different channels available where they can do this:


  • If the disclosure contains allegations against a Fishburners Team member, you can report to the Fishburners Chair of Board; [email protected]

Updates of incident:

Once your incident has been reported, the Fishburners Management Team will take all precautions and steps necessary to action the specified report.

  • Continuous updates will be provided to the informant throughout the progression of the investigation.
  • These updates can include the following:
    • Fishburners has confirmed the receipt of a report from the informant.
    • Fishburners has begun the investigative process.
    • The investigation is currently ongoing.
    • The investigation has been closed.
  • Fishburners commitment is that the informant will be updated once a month while the investigation is ongoing. They will then be updated once the investigation has been closed.
  • Fishburners will strive to provide as much feedback on the investigation as possible.

If the incident is dealt with by the Chair of Fishburners Board, the Chair will update you accordingly via email.