Respect, integrity and accountability are fundamental values of Veriu Group. In support of these values, Veriu Group aims to foster a culture of lawful, ethical conduct and good corporate governance.
The purpose of this policy is to:
Capitalised terms used throughout this policy are defined in the Table of Terms located in section 10 of this policy.
This policy applies to all Veriu Group team members, as well as the other persons defined as an Eligible Discloser in the Table of Terms.
This policy applies to matters that are, or may be, a Disclosable Matter. A Disclosable Matter may be something an Eligible Discloser has actual knowledge has occurred, or something they suspect has occurred, so long as they have arrived on such suspicion with reasonable grounds. Some examples of Disclosable Matters are the following:
The Table of Terms contains a more extensive list of the types of issues that may be a Disclosable Matter.
Issues that are solely Personal Work-Related Grievances are not Disclosable Matters under this policy, and do not qualify for protection under the Whistleblowing Laws. If your matter is a Personal Work-Related Grievance, then Veriu Group encourages you to address your concern by following the process contained in Veriu Group’s Grievance Policy.
It is possible for an Eligible Discloser to still qualify for protection under the Whistleblowing Law even if their disclosure turns out to be incorrect, so long as they had reasonable grounds to suspect that a Disclosable Matter existed at the time their disclosure was made.
To enable disclosures to be addressed in a timely manner, Veriu Group encourages Eligible Disclosers to report Disclosable Matters to one of our Nominated Whistleblower Officers listed below:
Reports may also be made in person or posted to the Nominated Whistleblower Officer at Veriu Group’s Corporate Office located at Suite 13.03, Level 13, 484 St Kilda Road, Melbourne VIC 3004.
Disclosable Matters may also be reported to:
Further details of these recipients are provided in the Table of Terms.
As much information as possible should be included in a disclosure made under this policy, together with the extent that the Eligible Discloser consents to their identity being disclosed to the Whistleblower Response Team or other persons involved in any potential investigation.
The kind of information that should be provided is contained in the example Whistleblowing Report in Annexure A to this policy. The use of the report in Annexure A is helpful but not mandatory. Disclosures made in writing to Veriu Group not using the form in Annexure A, should be labelled as a “Whistleblowing Report” to enable the disclosure to be dealt with in an appropriate and timely manner.
Disclosures may be made anonymously, and Eligible Disclosers may elect to remain anonymous over the course of any resulting investigation, including after it has been finalised. In addition, disclosures may be made on a partially anonymous basis, and Eligible Disclosers may adopt a pseudonym for the purpose of making a disclosure.
If a report is made on an anonymous basis, Veriu Group would prefer ongoing two-way communication is maintained, to assist with follow-up questions and to provide feedback. Eligible Disclosers may refuse to answer questions in such conversations with Veriu Group if they feel their identity could be revealed.
While it is the Eligible Discloser’s choice as to whether they disclose their identity, if a report is made entirely anonymously it may limit the scope of any investigation into the subject matter.
Persons who make a Qualifying Disclosure are referred to as a “Whistleblower” in this policy and are protected by the Whistleblowing Laws in the manner detailed below in sections 5.1 to 5.4. The Whistleblowing Laws contain specific requirements for a disclosure of information to be considered a Qualifying Disclosure, further information on these requirements is contained in the Table of Terms.
If the Whistleblower’s report is made to a member of Veriu Group, then their identity, and any information that may identify them, is required to be kept confidential by Veriu Group unless the Whistleblower provides consent for their identity to be disclosed. Veriu Group is permitted to disclose a Whistleblower’s identity only in the following circumstances:
Veriu Group may disclose other information contained in a Qualifying Disclosure, with or without the Whistleblower’s consent, so long as:
It is unlawful for a member of Veriu Group to disclose a Whistleblower’s identity, or information that is likely to lead to identification of a Whistleblower outside of the circumstances outlined above.
The relevant Whistleblowing Law should be consulted, and independent legal advice sought, regarding the identity protection obligations applicable to recipients external to Veriu Group.
It is an offence under the Whistleblowing Laws for anyone to engage in conduct that causes a person detriment if they believe or suspect that person has made, or proposes to make, a Qualifying Disclosure. It is also an offence for anyone make threats to cause detriment, whether that threat is express or implied. Examples of detriment include, but are not limited to:
However, the following actions taken by Veriu Group would not be considered detrimental conduct:
Whistleblowers may seek compensation, and other remedies, through the courts if:
Whistleblowers should seek independent legal advice if they wish to seek compensation or another remedy through the courts.
5.4 Civil, criminal and administrative liability protection
The Whistleblowing Laws provide Whistleblowers with protection from the following in relation to their disclosure:
These protections do not grant Whistleblowers immunity for any misconduct they have engaged in that is revealed in their disclosure.
Veriu Group will use a combination of the following measures to support Whistleblowers and protect them from experiencing detriment as a result of reporting a Disclosable Matter.
Current Veriu Group team members can access independent and confidential counselling through OCP by calling 1800 319 811 or book a session online at https://myocp.co/au – and advise you would like some support and that you work for Veriu Group.
Veriu Group will take the following steps to reduce the risk of a Whistleblower being identified from the information they provide, and to maintain confidentiality in a Qualifying Disclosure:
In practice, and despite the best endeavours of the people involved, other people may be able to guess a Whistleblower’s identity if:
As soon as possible after a Qualifying Disclosure is received, Veriu Group will conduct a risk assessment of potential detriment to enable the provision of pro-active support measures to the Whistleblower. The nature and extent of protective measures provided will depend on the Whistleblower’s role within, or connection to, Veriu Group and the subject matter of the Qualifying Disclosure. By way of example, for Whistleblowers who are current Veriu Group team members the following measures may be appropriate:
If a Whistleblower believes they have suffered detriment as a result of their disclosure, then they should notify Veriu Group as soon as possible. This notification can be made to a Nominated Whistleblower Officer or Other Veriu Group Recipient, and does not have to be made to the recipient of the original Qualifying Disclosure.
Breaches of confidentiality by Veriu Group team members, or actions that cause a Whistleblower detriment, are considered serious misconduct, and will result in disciplinary action.
A Whistleblower may also make a complaint of detriment to ASIC, APRA or the ATO.
Veriu Group will provide fair treatment to all team members mentioned in a Qualifying Disclosure, including team members who are the subject of a Qualifying Disclosure, by:
The Table of Terms below contains definitions and additional information for capitalised terms used in this policy.