Whistleblower Policy

Purpose

Future Leadership Pty Ltd and its controlled entities (Future Leadership) is committed to the highest standards of conduct and ethical behaviour including compliance with the legal environment in which it operates.

To reinforce this commitment, Future Leadership encourages the reporting of any instances of suspected breaches of the Code of Conduct, including any unethical, illegal, or undesirable conduct involving Future Leadership or any of its representatives (including employees and associates). It is important that people feel safe in speaking up, so Future Leadership will provide protections so that anyone making a report may do so without fear of reprisal, intimidation, or disadvantage.

Scope

The scope of this policy is to provide very clear guidelines on how Future Leadership approach and manage the report of instances of suspected breaches. With the whistleblowing policy, Future Leadership aims to ensure:

• Everyone should have the chance to speak up when they feel Future Leadership is not adhering to its corporate values and standards. They should have a place to report misconduct, every report will be heard and acted on, and Future Leadership will make improvements based on the results.
• Everyone should be able to make reports anonymously. Future Leadership commits to protecting informant’s identities and they only need to reveal themselves if they choose to.
• Future Leadership will investigate every report of misconduct. At the end of the investigation, Future Leadership will document the results and provide feedback when appropriate.

What conduct should be reported

Future Leadership want to hear about any behaviour that is:

• Fraudulent;
• Illegal;
• Corrupt;
• Dishonest;
• Unethical;
• Violates the law or any legal code;
• Is creating an unsafe environment;
• Breaches any of the company’s policies;
• Discrimination;
• Harassment and/or bullying of any kind;
• Any conduct which is detrimental to Future Leadership and could cause financial or non-financial loss.

Process of making a report

If a person would like to make a report, they have different channels available where they can do this.

• Speak with a member of the leadership team
• Speak with a member of the Board of Directors
• Letter addressed to Whistleblower or an email sent to [email protected]
• Letter addressed to Privacy Officer or an email sent to [email protected]

Whistleblower can remain anonymous

Future Leadership respects and protects the identity of people who report instances of suspected breaches. Whistleblowers can choose to remain anonymous while making a report, interacting with case managers during an investigation of the report, as well as after the case is closed.

If an identity is disclosed, Future Leadership will still work to protect the person’s identity and will outline and document who in the organisation will know the identity of the person that has submitted a report. Future Leadership will also take all steps necessary (and outlined in this policy) to ensure a person does not suffer any retaliation.

It is worth noting that Future Leadership will make every endeavour possible to investigate the report, but in some cases, there are limitations of what can be achieved if the informant decides to remain anonymous.

What is the investigative process?

When a report is received to the Whistleblower, Future Leadership’s Legal Counsel will do an initial assessment and confirm it is a valid report, and there is sufficient information to proceed to an investigation. Where a report is made to the Privacy Officer, it will be conducted by the Privacy Officer.

Depending on the nature of the report made, Future Leadership may engage independent third parties to undertake any investigation, and could include HR consultants, accountants, or investigative firms as appropriate.

Upon completion of the investigation, a report will be prepared and submitted to the Managing Director or Chair of the Board as appropriate to the nature of the issue. Recommendations as to resolution or action will then be implemented by the Managing Director or Board.

What is the process of updating the person making the report?

As part of the investigative process, Future Leadership will update the person who made the report of the progress of the investigation. Future Leadership will strive to provide as much feedback on the investigation as possible. However, due to privacy considerations, there is at times information that cannot be shared with the person who made the report.

How potential retaliation will be managed

A person making a report might be concerned that employees, associates, management, or the organisation might retaliate against them. In this case, Future Leadership will protect the informant from:

• Being terminated or having their employment ceased;
• Performance management;
• Harassment on the job or workplace bullying;
• Warnings or disciplinary actions;
• Discrimination;
• Any other action that can be perceived as retaliation for making a report.

How Future Leadership deals with retaliation

Future Leadership does not tolerate any attempts to retaliate against a person who has made a report. Any employee or associate that is found retaliating will face disciplinary action, including the potential to be terminated from their roles.

Separation of issues

Future Leadership will still be able to raise any issues related to work or performance related issues. While Future Leadership will protect the person making the report from any retaliation, it is also important that team members are still effective in their job. Future Leadership can still raise any performance or contract issues with the informant, but they will be separated and not influenced at all from any reports that have been made.

Protection for others

Other parties that might have to bear witness or are involved in the investigation will be protected from retaliation in the same manner as the person making the report.

Legislative/regulation protection & assistance

If in any jurisdictions or locales where Future Leadership operates has whistleblowing protection laws that provide a higher level of protection than what is included in this policy, the local legislation will take precedence.

Governance

From time to time, Future Leaderships’ whistleblowing policy will need to change to align with the company’s values, best practices, and improvements, as well as legislation and regulations. Any changes to the whistleblowing policy will be communicated with all employees and any relevant stakeholders.

All changes in the policy will be approved by the Board of Directors.

Reporting to the Board of Directors

The Board of Directors is updated every quarter on the whistleblowing program, inclusive of reports, investigations, and results. Reports or investigations carrying an undue amount of risk will be reported to the Board of Directors outside of the quarterly updates.