Whistleblower Policy

Whistleblower Policy

Introduction

IC Care is committed to fostering a culture of legal, ethical and moral behaviour and exemplary corporate governance. The organisation recognises the value of transparency and accountability in its administrative and management practices and supports the reporting of improper conduct.

This Policy and its procedures have been developed so that people can raise concerns regarding situations where they believe that IC Care or anybody connected with IC Care has acted in a way that constitutes serious wrongdoing, including unethical, illegal, corrupt or other inappropriate conduct.

Purpose

This Policy aims to:

1. Encourage a person to report improper conduct in good faith if they know or have reasonable grounds to suspect such conduct;
2. Provide a mechanism to report misconduct or dishonest or illegal activity that has occurred or is suspected within the organisation;
3. Enable IC Care to deal with reports from whistleblowers in a way that will protect the identity of the whistleblower and provide for secure storage of the information;
4. Ensure that any Reportable Conduct is identified and dealt with appropriately;
5. Ensure that individuals who disclose wrongdoing can do so safely, securely and with confidence that they will be protected and supported; and
6. Help to ensure that IC Care maintains the highest standards of ethical behaviour and integrity.

Scope

This Policy applies to the following individuals:

Employees	Directors	Officers	Contractors	Volunteers	Suppliers	Consultants
✔	✔	✔	✔	✔	✔	✔

Within this policy all of these people are represented by the term “Workers”. Associates, family members or dependants may also speak up and will receive the same protections.

Responsibility

The CEO is responsible for ensuring workers are informed of their rights and responsibilities and encouraged to speak up.

The Whistleblower Program Team (WP Team) — comprising the CEO and Chair of the Board — is responsible for receiving, assessing, and managing reports, maintaining confidentiality, appointing investigators, and overseeing actions and reporting.

The Independent Investigator is responsible for conducting fair, objective investigations, maintaining confidentiality, preserving evidence, and reporting findings to the WP Team.

Workers are responsible for promptly reporting misconduct, whether anonymously or otherwise.

Principles

• Higher Standard: Legal obligations take precedence over this Policy.
• Speak Up: Workers are encouraged to report any concerns in line with IC Care’s policies.
• Expectations: Reports should be made honestly and on reasonable grounds.
• Confidentiality: IC Care will maintain the confidentiality of reports to the fullest extent possible.

Who Can Make a Report?

A Whistleblower may be any current or former Worker of IC Care who reports misconduct or illegal activity and seeks protection under this Policy.

What Information Do I Need to Make a Report?

Provide as much detail as possible, including:

• Date, time and location of events;
• Names of people involved;
• Possible witnesses; and
• Supporting evidence such as documents or emails.

Reportable Conduct

Examples of Reportable Conduct include dishonest, corrupt, fraudulent, illegal or unsafe behaviour, breaches of policy, mismanagement of resources, and concealment of wrongdoing.

What Is Not Reportable Conduct?

Personal work-related grievances (e.g. interpersonal conflicts or employment decisions) are not covered unless they involve victimisation or whistleblower retaliation.

Protection

IC Care will protect anyone who reports Reportable Conduct in good faith from retaliation, dismissal, harassment, discrimination, or any detriment. Confidentiality will be maintained, and legal protections under the Corporations Act 2001 (Cth) apply.

Confidentiality

Reports may be made anonymously. IC Care will safeguard identity and only disclose it under lawful exceptions such as consent, regulator requests (ASIC, APRA, AFP), or legal advice.

False Reports

Knowingly making a false report may result in disciplinary action, including dismissal, depending on the severity and circumstances.

Monitoring and Assurance

This Policy is reviewed annually by the WP Team and distributed to all Workers via orientation materials and the Policy Manual.

Procedures

How to Make a Report

Reports should be made to the WP Team or, if not possible, to an external regulator such as ASIC. Protections apply only to reports made under this Policy.

Investigation Process

The WP Team will assess, determine conflicts of interest, decide on notifications to authorities, and appoint an independent investigator if needed. Investigations are conducted fairly, objectively, and in a timely manner.

Investigation Outcome

Upon conclusion, a report is prepared summarising findings and recommendations. Disciplinary actions may follow based on severity. Where appropriate, the whistleblower will be informed of the outcome.

Reviewed 30/10/2025 © IC Care – Whistleblower Policy | Reviewed Annually