Whistleblower Policy

Stratabase Whistleblower Policy

Purpose

This policy encourages the reporting of misconduct or illegal activity and provides mechanisms for safe, confidential, and protected disclosures within Stratabase.

Scope

Applies to all officers, employees, contractors, suppliers, and associates of Stratabase.
Covers disclosures about misconduct, breaches of law, improper conduct, or any danger to the public or financial system.

Eligible Whistleblowers

A person is considered an “eligible whistleblower” if they are or were an employee, officer, contractor, supplier or an associate of Stratabase.
Family members and dependants of the above may also qualify.

Disclosable Matters

Reportable conduct includes actual or suspected misconduct, illegal activity, or breaches as defined under the Corporations Act, ASIC Act, or other relevant laws.
Disclosures must be based on reasonable grounds to suspect wrongdoing.

Making a Disclosure

Disclosures can be made to eligible recipients including: Stratabase’s senior managers or officers, auditors, or designated external reporting channels, as well as to ASIC, APRA, or a legal practitioner.
Anonymous disclosures are permitted and protected.

Investigation Process

Each disclosure will be assessed and, if necessary, investigated objectively, fairly, and independently.
The whistleblower may be kept informed of the progress, subject to confidentiality requirements.
Confidentiality is paramount; the identity of the whistleblower must not be disclosed without their consent, except as required by law.

Protections for Whistleblowers

No retaliation or victimisation is permitted against whistleblowers.
Whistleblowers are protected from civil, criminal, and administrative liability for making a qualifying disclosure.
Compensation must be provided for any damage or harm resulting from retaliation.

Fair Treatment of Involved Employees

Employees named in disclosures are entitled to fair treatment, including being advised of claims and allowed to present their case before any action is taken.
Investigations are handled confidentially and records are maintained.

Support and Implementation

Stratabase will provide support services, such as access to employee assistance programs.
The policy will be communicated to all staff and made publicly available.
Regular reviews and training will ensure ongoing compliance and effectiveness.

Additional Notes

Stratabase must comply with all updates from ASIC, APRA, and new statutory authorities established (such as a Whistleblower Protection Authority).
Non-compliance may result in significant penalties.

Policy Updates

This policy is reviewed regularly and updated to reflect changes in law, operations, or technology. Updates will be published on the Stratabase website and communicated to users.