Main menuWhistleblower policy
Overview
At Gallagher Hotels (Jackson’s) Pty Ltd (“Company”) we are guided by our company values. These values are the foundation of how we conduct ourselves and interact with each other, our clients, members, suppliers, shareholders and other stakeholders. The Company is committed to ensuring corporate compliance and promoting ethical corporate culture by observing the highest standards of fair dealing, honesty and integrity in our business activities.
Purpose
The policy has been put in place to ensure any concerns raised regarding any misconduct or improper state of affairs or circumstances in relation to the Company’s business are dealt with effectively, securely, appropriately and in accordance with the Corporations Act 2001 (Cth) (the Act).
The Company encourages the reporting of any instances of suspected unethical, illegal, corrupt, fraudulent or undesirable conduct involving the Company’s business and provides protections and measures to individuals who make a disclosure in relation to such conduct without fear of victimisation or reprisal.
This policy will be provided to all employees and officers of the Company upon commencement of their employment or engagement. The policy is also available to persons outside the organisation.
The Company may invite officers, senior management and employees to attend training sessions to ensure ongoing education regarding the application of the policy.
Scope
This policy applies to any person who is, or has been, any of the following with respect to the Company:
- Employee
- Officer
- Director
- Contractor (including sub-contractors and employees of contractors)
- Supplier (including employees of suppliers)
- Consultant
- Auditor
- Associate
- Relative, dependant, spouse, or dependant of a spouse of any of the above.
Reportable conduct
You may make a report or disclosure under this policy if you have reasonable grounds to believe that a Company director, officer, employee, contractor, supplier, consultant or other person who has business dealings with the Company has engaged in conduct (Reportable Conduct) which is:
- dishonest, fraudulent or corrupt;
- illegal (such as theft, dealing in or use of illicit drugs, violence or threatened violence and criminal damage to property);
- unethical including any breach of the Company’s policies such as the Code of Conduct;
- oppressive or grossly negligent;
- potentially damaging to the Company, its employees or a third party;
- misconduct or an improper state of affairs;
- a danger, or represents a danger to the public or financial system; and/or
- harassment, discrimination, victimisation or bullying.
Any disclosures that do not fall within the definition of Reportable Conduct will not qualify for protection under the Act. It will be at the Company’s discretion whether it considers there is a reasonable suspicion that the Reportable Conduct is occurring and/or whether the conduct constitutes “misconduct or improper state of affairs” under the Act.
For the avoidance of doubt, Reportable Conduct does not include personal work-related grievances. A personal work-related grievance is a grievance about any matter in relation to a staff member’s current or former employment, having implications (or tending to have implications) for that person personally and that do not have broader implications for the Company. Examples of personal work-related grievances are as follows:
- an interpersonal conflict between the staff member and another employee;
- a decision relating to the engagement, transfer or promotion of the staff member;
- a decision relating to the terms and conditions of engagement of the staff member; and
- a decision to suspend or terminate the engagement of the staff member, or otherwise to discipline the staff member.
Personal work-related grievances should be reported to a manager or in accordance with the Company’s Grievance Policy.
Making a disclosure
The Company relies on its employees maintaining a culture of honest and ethical behaviour. Accordingly, if you become aware of any Reportable Conduct, it is expected that you will make a disclosure under this policy.
There are several ways in which you may report or disclose any issue or behaviour which you consider to be Reportable Conduct.
Internal Reporting
You may disclose any Reportable Conduct to the Whistleblower Protection email listed below:
You can make a disclosure outside of business hours by contacting the above Whistleblower Protection Officer via email.