Whistleblower Policy

As a proprietary company of our size, Cactive Pty Ltd isn’t required to have a whistleblower policy. We have one because we want people to tell us about wrongdoing, and to be protected when they do. The protections in Part 9.4AAA of the Corporations Act 2001 (Cth), and in the Taxation Administration Act 1953 (Cth) for tax matters, apply where the law says they do.

Current and former directors, employees, contractors and suppliers of Cactive, and their relatives and dependants, can report misconduct or an improper state of affairs, such as:

• fraud, bribery, theft or other crimes
• breaches of privacy, consumer, tax or corporations law
• serious risks to people’s safety, or to the public
• modern slavery in our business or supply chain
• retaliation against someone who has spoken up

Personal work grievances, such as a dispute about your own pay or a performance decision, generally aren’t covered, unless they involve retaliation or a wider problem.

• Confidentially, to our legal and privacy officer at legal@cactive.com.au, or to a director.
• Anonymously if you prefer, for example from an email address that doesn’t identify you.

Other eligible recipients

Under the Corporations Act you can also report to our officers, senior managers or auditor, to ASIC or APRA, or to a lawyer for advice about the protections. Tax matters can go to the Australian Taxation Office. In limited cases the law protects public interest and emergency disclosures to a journalist or a member of parliament; get advice before you make one.

• We acknowledge your report if we can reach you, and look into it fairly and as soon as we can.
• The person who handles it won’t be someone it’s about. If it concerns a director, it goes to the others.
• We tell you how it ends, as far as we can without breaching anyone’s privacy or the law.

• We keep your identity confidential, and share it only with your consent or where the law allows, such as with ASIC, the police or a lawyer.
• No one may dismiss, demote, harass, threaten or otherwise harm you for speaking up, or because they think you have. We treat retaliation as serious misconduct.
• If you suffer harm, the law may entitle you to compensation and other remedies. These protections apply to reports made on reasonable grounds, even if they turn out to be wrong.

ASIC explains whistleblower protections at asic.gov.au/whistleblowing. This policy sits with our Code of Conduct.