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    1. Introduction

    This Policy sets out how to make a whistleblowing disclosure and how Squiz Pty Limited and its affiliates (the Group) manage whistleblower disclosures. The Group is committed to transparency and to building an environment in which people feel free to raise any instances of suspected unethical, illegal, fraudulent, or undesirable conduct involving the Group's businesses whilst providing protections and measures so that those persons who make a report may do so confidentially and without fear of intimidation, disadvantage or reprisal.

    2. Purpose

    The purpose of this Policy is to set out information relating to whistleblowing at Squiz, including information about:

    1. the types of disclosures that qualify for protection;
    2. the protections available to whistleblowers;
    3. who disclosures can be made to and how they can be made;
    4. how the Group will support whistleblowers and protect them from detriment;
    5. how the Group will investigate disclosures;
    6. how the Group will ensure fair treatment of employees who are the subject of or are mentioned in disclosures; and
    7. how this Policy is to be made available to officers and employees of the Group.

    3. Application

    This Policy applies to all directors and employees of the Group and external whistleblowers, including suppliers and their employees and relatives. The objectives of this Policy are to provide clarity on how we support whistleblowers so that they:

    1. know how to raise concerns and are aware of their rights and obligations, including the right to remain anonymous; and
    2. feel safe in speaking up and raising concerns, free from detriment, retaliation or victimization.

    The Group is committed to complying with applicable laws to protect whistleblowers. In addition to the protections under this Policy some jurisdictions provide additional protection:

    Australia

    The Corporations Act provides specific protections to whistleblowers who disclose information concerning misconduct or an improper state of affairs or circumstances in relation to the Group, which may include a breach of legislation including the Corporations Act, an offense against the Commonwealth punishable by imprisonment for 12 months or more, or conduct that represents a danger to the public or financial systems.

    The Taxation Administration Act provides specific protections to whistleblowers on tax-related matters.

    United Kingdom

    The Public Interest Disclosure Act 1998 protects whistleblowers from detrimental treatment by their employer as a result of making a public interest disclosure.

    4. Who is a whistleblower?

    For the purposes of this Policy, a whistleblower is a current or former:

    1. director, manager or employee;
    2. contractor, consultant, supplier, service provider or associate (or their employees or subcontractors); or
    3. any relative, dependent or spouse of any individual referred to above, who may make a report under this Policy if they have reasonable grounds to suspect that a Group director, officer, employee, contractor, supplier, tenderer or other person who has business dealings with the Group has engaged in conduct (Reportable Conduct) which:
      1. is dishonest, fraudulent or corrupt, including bribery or other activity in breach of the Group Anti-bribery and Corruption Policy;
      2. is illegal activity (such as theft, violence, harassment or intimidation, criminal damage to property, breach of competition and consumer law, breach of privacy law or other breaches of state or federal law);
      3. is unethical or in breach of  the Group's policies (such as dishonestly altering company records or data, adopting questionable accounting practices or wilfully breaching the Group Code of Conduct or other policies or procedures);
      4. is potentially damaging to the Group, a Group employee or a third party such as unsafe work practices, environmental damage, health risks or abuse of the Group's property of resources;
      5. amounts to an abuse of authority or a conflict of interest;
      6. may cause financial loss to the Group or damage its reputation or be  otherwise detrimental to the Group's interests;
      7. involves harassment, discrimination, victimisation or bullying, other than personal work-related grievances; or
      8. involves any other kind of misconduct or an improper state of affairs or circumstances.
    4. Reportable Conduct generally does not include personal work-related grievances. A disclosure is a 'personal work-related grievance' if:
      1. the information concerns a grievance about a matter relating to the eligible whistleblower's employment, or former employment, having (or tending to have) implications for the eligible whistleblower personally; and
      2. the information:
        1. does not have significant implications for the Group, or another regulated entity, that do not relate to the discloser; and
        2. does not concern conduct, or alleged conduct, that is Reportable Conduct.
    5. Examples of personal work-related grievance include:
      1. an interpersonal conflict between the discloser and another employee;
      2. a decision relating to the employment, transfer, or promotion of the discloser;
      3. a decision relating to the terms and conditions of employment of the discloser;
      4. a decision to suspend or terminate the employment of the discloser, or otherwise to discipline the discloser.

    Such matters should be raised directly with your manager or through the Group's People & Culture Department.

    5. Making a disclosure

    The Policy applies where a whistleblower makes the disclosure to an eligible recipient (Eligible Recipient).  An Eligible Recipient includes

    1. a person authorised by the Group to receive disclosures which include directors, executive committee members (being senior managers), lead HR, and internal legal counsel, and
    2. an officer, auditor or actuary of the Group.
    3. If appropriate, it is recommended that employees initially direct any report to their immediate manager.
    4. A disclosure may also be protected if:
      1. made to certain regulators or legal practitioners; or
      2. if it is a 'public interest disclosure' or 'emergency disclosure' made to journalists or parliamentarians, in certain circumstances where previous disclosure has been made to prescribed government bodies.

    Whistleblowers should contact an independent legal adviser before making a ‘public interest disclosure’ or an ‘emergency disclosure’.

    6. How to make a disclosure

    A disclosure can be made:

    1. by an email to: whistleblowingreport@squiz.net (the recipients being lead HR and internal legal counsel); or
    2. in writing, by telephone, or in-person to an Eligible Recipient.

    7. Anonymous disclosures

    An eligible whistleblower can choose to make a disclosure anonymously. For example, they may do so because of concerns about their identity becoming known. If such concerns exist, an eligible whistleblower may prefer to adopt a pseudonym for the purposes of their disclosure (not their true name) – or to create an anonymous email address to submit their disclosure to an Eligible Recipient. Regardless, anonymous disclosures are still capable of being protected.

    In some cases, though, it may be more difficult for the Group to investigate an anonymous disclosure. However, it may be possible to address this if the whistleblower provides a means of contact for any follow-up questions (e.g. via an anonymous email address).

    8. Protection of whistleblowers

    The Group is committed to ensuring confidentiality in respect of all matters raised under this Policy and that those who make a report are treated fairly and do not suffer detriment. These protections are summarised below:

    1. Protection against detrimental treatment
      Detrimental treatment includes dismissal, demotion, harassment, discrimination, disciplinary action, bias, threats, or other unfavourable treatment connected with making a report.

      If you are subjected to detrimental treatment as a result of making a report under this Policy, you should inform an Eligible Recipient within your division/business unit immediately.
    2. Protection of your identity and confidentiality
      Subject to compliance with legal requirements, upon receiving a report under this Policy, the Group will take reasonable steps to keep your identity confidential and reduce the risk of disclosure in the course of an investigation and will only share your identity as a whistleblower or information likely to reveal your identity if:
      1. you consent;
      2. the concern is reported to a regulator responsible for the subject of your disclosure; or
      3. the concern is raised with a lawyer for the purpose of obtaining legal advice or representation.
    3. Protection of files and records
      All files and records created from an investigation will be retained securely. Unauthorized release of information to someone not involved in the investigation (other than senior managers or directors who need to know to take appropriate action, or for corporate governance purposes) without your consent as a whistleblower may be considered a breach of this Policy.
    4. Compensation and remedies
      Courts are given broad scope to make orders remedying a detriment or threatened detriment. These include injunctions, compensation orders (including against individual employees and their employer), reinstatement, exemplary damages, and the making of apologies. Civil and criminal sanctions may also apply.
    5. Civil, criminal and administrative liability protection
      Any disclosures of your identity or information likely to reveal your identity will be made on a strictly confidential basis.

      An eligible whistleblower is protected from any civil liability, criminal liability, or administrative liability (including disciplinary action) for making a qualifying disclosure, and no contractual or other remedy may be enforced or exercised, against the eligible whistleblower on the basis of a qualifying disclosure. However, the protections do not grant immunity for any misconduct a discloser has engaged in that is revealed in their disclosure.

    9. Investigation

    The Group will investigate matters reported under this Policy as soon as practicable after the matter has been reported.

    An Eligible Recipient may, with your consent, appoint a person to assist in the investigation of a report. Where appropriate, the Group will provide feedback to you regarding the progress of the investigation and/or outcome (subject to considerations of the privacy of those against whom allegations are made).

    Any investigation will be conducted in an objective and fair manner, and otherwise as is reasonable and appropriate having regard to the nature of the Reportable Conduct and the circumstances.

    While the particular investigation process and inquiries adopted will be determined by the nature and substance of the report, in general, as soon as practicable upon receipt of the report, if the report is not anonymous, an Eligible Recipient or investigator will contact you to discuss the investigation process including who may be contacted and such other matters as are relevant to the investigation.

    Where a report is submitted anonymously, the Group will conduct the investigation based on the information provided to it.

    10. Availability

    This Policy will be made available to employees and officers of the Group via the intranet, by email (on request to the Group), and made available on the Group’s website.

    This policy is not a term of any contract, including any contract of employment, and does not impose any contractual duties, implied or otherwise, on the Group.

    This policy may be varied by the Group from time to time.

    Australia: For further information on whistleblowing protections and general information on whistleblowing can be obtained from the ASIC website: www.asic.gov.au/aboutasic/asic-investigations-and enforcement/whistleblowing/.