Whistleblower Policy

Status: v2.0
Tier: Tier 1 – Core Corporate & Platform Policy
Owner: Governance and Compliance Function
Approval Authority: Board of Directors
Effective Date: 5 January 2026
Next Review: 12 months from approval

1. Purpose

This Whistleblower Policy encourages the reporting of serious wrongdoing connected with Global Talent Pathway and provides protections for individuals who make such disclosures in good faith.

Its purpose is to:

  • support early detection of serious misconduct,

  • protect whistleblowers from retaliation,

  • ensure lawful handling of disclosures, and

  • meet obligations under applicable whistleblower protection laws.

This policy applies to whistleblower disclosures only, not to general complaints or grievances.

2. Relationship to the Complaints & Disclosures Gateway

All whistleblower disclosures are made through the Complaints & Disclosures Gateway.

No separate whistleblower reporting pathway exists.

Gateway intake and triage determine whether a report qualifies as a whistleblower disclosure and which protections apply.

3. Scope

This policy applies to whistleblower disclosures made by:

  • current and former employees,

  • contractors and consultants,

  • suppliers and service providers,

  • officers, Board members, and Advisory Board members,

  • associates, relatives, or dependants of the above, where permitted by law.

This policy applies across all Global Talent Pathway activities and jurisdictions, subject to applicable law.

4. What Is a Whistleblower Disclosure

A whistleblower disclosure is a report of suspected or actual serious wrongdoing that:

  • affects Global Talent Pathway or others,

  • does not primarily concern a personal work-related grievance, and

  • is disclosed in good faith.

5. Disclosable Matters

Disclosable matters may include:

  • breaches of law or regulation,

  • fraud, bribery, or corruption,

  • serious misconduct or unethical behaviour,

  • modern slavery or labour exploitation,

  • serious breaches of Global Talent Pathway policies,

  • conduct that poses a significant risk to people, data, finances, or reputation,

  • deliberate concealment of wrongdoing.

Personal work-related grievances are not whistleblower disclosures unless they:

  • involve victimisation for whistleblowing,

  • have broader systemic implications, or

  • relate to misconduct beyond the individual.

6. Making a Disclosure

Disclosures are made through the Complaints & Disclosures Gateway, which supports:

  • confidential reporting,

  • anonymous reporting, and

  • secure handling.

Whistleblowers are encouraged to provide as much information as possible, but are not required to prove their concerns.

7. Confidentiality

Global Talent Pathway will take reasonable steps to protect the identity of a whistleblower.

Identity information will not be disclosed except:

  • with the whistleblower’s consent, or

  • where required or permitted by law.

Information may be shared on a strictly need-to-know basis for investigation and response.

8. Protection from Retaliation

Global Talent Pathway prohibits retaliation against whistleblowers who make disclosures in good faith.

Retaliation includes:

  • dismissal or termination,

  • demotion or disadvantage,

  • harassment or intimidation,

  • discrimination or adverse treatment.

Retaliation may result in disciplinary action or termination of relationships.

9. Handling and Investigation

Following gateway triage:

  • disclosures are assessed for credibility and risk,

  • investigations are conducted proportionately and independently,

  • external investigators may be engaged where appropriate.

Not all disclosures will lead to a formal investigation.

10. Outcomes

Outcomes may include:

  • no action (where allegations are unsubstantiated),

  • corrective or disciplinary action,

  • changes to controls or processes,

  • referral to authorities where required by law.

Where appropriate and lawful, whistleblowers may be informed of progress or outcomes.

11. False or Malicious Reports

Disclosures made knowingly false or maliciously may result in disciplinary or other action.

This does not apply to disclosures made in good faith that are later unsubstantiated.

12. Recordkeeping

Whistleblower disclosures are:

  • recorded securely,

  • access-restricted,

  • retained in accordance with the Records Management & Retention Policy.

13. Relationship to Other Policies

This policy operates alongside:

  • Complaints Policy,

  • Modern Slavery & Human Trafficking Policy,

  • Ethical Recruitment & Fair Work Policy,

  • Fraud, Bribery & Corruption Policy.

In the event of inconsistency, Tier 1 policies prevail.

14. Review

This policy will be reviewed annually and updated as required.