Whistleblower Policy

Purpose

Vasey Communities is committed to operating with integrity, transparency, and accountability.

This Policy provides a framework for reporting and managing concerns regarding misconduct or improper conduct and ensures compliance with:

• Corporations Act 2001 (Cth) – Part 9.4AAA (Whistleblower protections)
• Aged Care Act 2024 (Cth) and Aged Care Rules 2025
• Applicable workplace and governance legislation

This Policy aims to:

• Encourage individuals to report wrongdoing
• Provide clear reporting pathways
• Ensure disclosures are managed fairly and promptly
• Protect whistleblowers from detriment
• Support ethical and lawful conduct across Vasey Communities

 Scope

This Policy applies to:

• Board Members and Responsible Persons
• Employees (current and former)
• Volunteers
• Contractors and suppliers
• Residents and their representatives

This Policy applies to disclosures relating to Vasey Communities’ operations, services, and governance.

What is Reportable Conduct

A disclosure may be made where there are reasonable grounds to suspect:

• Misconduct or an improper state of affairs
• Breaches of Commonwealth law
• Financial misconduct or misuse of resources
• Conduct that endangers health, safety, or wellbeing
• Breaches of duties by officers or employees
• Conduct that damages public trust or organisational integrity

Not Covered

This Policy does not apply to:

• Personal work-related grievances (unless systemic or serious misconduct)
• General complaints or dissatisfaction

These should be managed through the Complaints or Grievance processes.

Who Can Make a Disclosure (Eligible Whistleblowers)

Disclosures can be made by:

• Employees and former employees
• Officers and Board members
• Contractors, suppliers and their employees
• Volunteers
• Residents and their families

Who Can Receive a Disclosure (Eligible Recipients)

Disclosures that qualify for protection must be made to:

• Officers or senior managers of Vasey Communities
• Authorised recipients (e.g. CEO, Board members)
• An auditor or member of an audit team
• A legal practitioner (for advice)
• Regulatory bodies such as ASIC

Disclosures may also be made under the Aged Care Act to:

• Aged Care Quality and Safety Commission
• A registered provider or responsible person
• An aged care worker
• Law enforcement or an independent advocate

How to Make a Disclosure

Internal Reporting

You can report concerns to:

• Your Manager or Village Manager
• A Senior Leader
• Chief Executive Officer
• Board Member

Vasey Communities Contact Details

• Email: privacy@vasey.com.au
• Phone: (02) 9299 3951
• Mail:
  Confidential – Whistleblower Disclosure
  Vasey Community Housing - Suite 10G, Level 10, Rhodes Waterside Shopping Centre, 1 Rider Boulevard, Rhodes NSW 2138

External Reporting

If internal reporting is not appropriate, disclosures may be made to regulators including:

• Aged Care Quality and Safety Commission
• Fair Work Ombudsman
• ASIC

Protections for Whistleblowers

Confidentiality

• The identity of a whistleblower will not be disclosed without consent, except where permitted by law
• Information will be handled securely and shared only where necessary

Anonymity

• Disclosures can be made anonymously
• Anonymous reports will still be assessed where possible

Protection from Detriment

A whistleblower must not suffer detriment, including:

• Dismissal or demotion
• Harassment, bullying, or intimidation
• Psychological harm
• Reputational or financial damage

Any person engaging in such conduct may be subject to disciplinary or legal action.

Protection from Liability

Whistleblowers are protected from civil, criminal, and administrative liability when making a disclosure in good faith.

Investigation Process

All disclosures will be:

• Assessed promptly
• Managed confidentially
• Investigated where appropriate

Governance Roles

• Whistleblower Investigation Officer (WIO): Responsible for managing investigations : (COO)
• Whistleblower Protection Officer (WPO): Responsible for safeguarding the whistleblower : (CEO)

Process

Investigations may include:

• Reviewing documentation
• Interviewing relevant parties
• Engaging internal or external investigators

Fair Treatment

• All individuals are treated fairly
• Persons subject to allegations will be given an opportunity to respond

Outcomes

Outcomes may include:

• Corrective actions
• Disciplinary measures
• System improvements
• Referral to external authorities

Public Interest & Emergency Disclosures

A disclosure may be made to a journalist or Member of Parliament where:

• The matter has already been reported to a regulator
• At least 90 days have passed (public interest disclosure), or
• There is an immediate and serious threat (emergency disclosure)

Legal advice is recommended before making such disclosures.

Support for Whistleblowers

Vasey Communities will:

• Assess and respond to risks to the whistleblower’s wellbeing
• Implement measures to prevent victimisation
• Provide appropriate support throughout the process

Responsibilities

All individuals must:

• Act honestly and ethically
• Report concerns in good faith
• Cooperate with investigations

Leaders must:

• Promote a speak-up culture
• Ensure disclosures are managed appropriately
• Maintain confidentiality

Training & Awareness

Vasey Communities will:

• Provide training on the whistleblower framework
• Promote awareness of reporting options
• Ensure staff understand their obligations

Record Management

All whistleblower records will be:

• Stored securely
• Accessed only by authorised personnel
• Managed in accordance with privacy laws

Governance & Reporting

• De-identified reporting on whistleblower matters will be provided to the Board
• Trends and risks will be monitored to improve organisational practices

Accessibility

This Policy will be:

• Published on the Vasey Communities website
• Provided to residents, staff, and stakeholders
• Available in accessible formats (e.g. large print, translated versions)
• Supported with assistance where required

Compliance

Failure to comply with this Policy, including retaliation or breach of confidentiality, may result in disciplinary action or legal consequences.

Review

This Policy will be reviewed annually or required due to legislative or organisational changes.