Policy Overview
The Wandering Man, as a not-for-profit organisation, upholds a firm commitment to uncovering and preventing illegal conduct and other undesirable activities. Central to this commitment is our Whistleblower Policy, designed to provide a secure platform for employees and others to report concerns without fear of retribution.
Objectives
This Policy aims to
- Foster a culture that supports reporting of Potential Misconduct.
- Act as a preventive measure against Potential Misconduct, aligned with The Wandering Man’s risk management and governance.
- Assure individuals who report Potential Misconduct of protection and support.
- Ensure prompt and proper handling of disclosures.
- Offer clarity on procedures for receiving, managing, and investigating disclosures.
- Comply with legal and regulatory requirements.
The Wandering Man ensures protection for anyone reporting concerns (Speaking Up) and strictly prohibits retaliation.
Disciplinary action, which may include termination, will be enforced against anyone causing detriment to a whistleblower.
Scope
This Policy is applicable to
- Present and past employees (permanent, part-time, temporary, interns, secondees, and managers).
- Current and former officers or associates (such as directors or company secretaries).
- Providers of goods or services (both paid and volunteer), and their employees.
- Relatives, dependents, or spouses of individuals from categories (a) to (c).
Reportable Matters
The Wandering Man encourages reporting on instances of Potential Misconduct, including but not limited to:
- Legal or regulatory non-compliance.
- Violations of The Wandering Man’s Code of Conduct or policies.
- Detrimental conduct towards whistleblowers.
- Criminal activity; bribery; corruption.
- Health, safety, or environmental hazards.
- Unethical or dishonest conduct; conflicts of interest.
- Victimisation; harassment; modern slavery.
- Fraudulent financial or tax reporting.
- Data privacy breaches; misuse of confidential information.
- Any conduct posing public or financial system risks.
Personal work-related grievances that are not connected to broader misconduct or threats are not covered by this Policy.
Reporting Procedure
Concerns should ideally be reported to the Whistleblower Protection Officer (WPO). External parties may contact The Wandering Man’s Privacy Officer (email:hello@thewanderingman.com.au).
Reports received by Other Eligible Recipients (OERs) will be directed to the WPO, except under special circumstances.
Legal advice may be sought from a legal practitioner, and disclosures may also be made to regulatory bodies or, under specific conditions, to journalists or parliamentarians, following legal advice or guidance from the WPO.
Anonymity Disclosures can be made confidentially, anonymously, or under a pseudonym. However, non-anonymous reporting is preferred to aid a thorough investigation and ensure whistleblower support.
Protection for Whistleblowers
The Wandering Man commits to protecting the identity of whistleblowers and safeguarding them from detrimental actions. Breaches of confidentiality and retaliation are unlawful and will be subject to disciplinary measures.
Investigative Process Reports made under this Policy will be investigated objectively and promptly. The Whistleblower Investigation Officer (WIO) will lead the investigation, with potential assistance from external professionals. All relevant parties are expected to cooperate fully.
Confidentiality during the investigation is paramount, and whistleblowers will be kept informed throughout various stages.
Ongoing Updates and Policy Changes
The Board Chair and the Audit, Finance and Risk Committee (AFRC) will receive reports on findings and actions. This Policy is subject to review and updates will be posted on our website, effective from the date of posting.
The current iteration of the Policy is dated February 2024.
Definitions
Terms such as "The Wandering Man", "Potential Misconduct", "Speaking Up", "Whistleblower", "Whistleblower Investigation Officer" (WIO), "Whistleblower Protection Officer" (WPO) and "Other Eligible Recipients" (OER) are defined within the context of this Policy.
