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Planit Test Management Solutions Pty Ltd (Australia) (Planit or Company) values its culture of developing and fostering high standards of ethical and moral business conduct. Reflecting its commitment to transparency, this policy provides a mechanism by which protected disclosures can be made and investigated.
This policy applies to all eligible whistleblowers and eligible recipients as defined in this policy.
The policy is developed and implemented in accordance with the requirements of Part 9.4AAA of the Corporations Act 2001 (Cth) (the Act) as amended from time to time.
It will be made available to all applicable persons by way of the Company’s website. Employees and officers should review the internal Whistleblower Protection Policy available on Planit Connect, the Company people management system.
4. 1 What is a protected disclosure?
A disclosure of information by a person will be a protected disclosure under this policy and the Act if:
4.2 Who is an eligible whistleblower?
4.3 Who is an eligible recipient?
4.4 The protective officer
4.5 What is a disclosable matter?
Disclosable matters are information that is given (disclosed) by an eligible whistleblower where:
4.6 Is a personal work-related grievance a protected disclosure?
A disclosure of information by an individual concerning a personal work-related grievance does not qualify for protection (except where the grievance is about a breach of the whistleblowing protections).
4.7 What is an emergency disclosure?
Other than for disclosable matters that relate to tax affairs, an eligible whistleblower may make an emergency disclosure to a Member of Parliament or a journalist where:
4.8 What is a public interest disclosure under this policy?
Other than for disclosable matters that relate to tax affairs, an eligible whistleblower may make a public interest disclosure to a Member of Parliament or a journalist where:
4.9 Investigation of protected disclosures made to Planit
The Company will investigate all protected disclosures made under this policy, as is appropriate, as soon as reasonably practicable after the disclosure has been made. The following procedure applies where an eligible whistleblower discloses a disclosable matter to an eligible recipient at paragraphs 4.3(a)(i) and 4.3(a)(ii) above.
5.1 Protection from detriment
The company will support eligible whistleblowers and protect them from detriment in the following ways.
5.2 Protection of identity
Except in the circumstances specified below, the Company will not disclose the information, the identity of the eligible whistleblower and any information that is likely to lead to the identification of the eligible whistleblower, unless they agree.
5.3 Protection from certain liability
5.4 Compliance with protections for eligible whistleblowers
An employee or officer of Planit who fails to comply with clause 5.1(b), 5.3(a) or 5.3(b) may be subject to disciplinary action up to and including termination of employment. Such a person may also be in breach of the law, which may result in:
5.5 Protection of files and records
All files and records created from an investigation will be securely retained.
5.6 Additional support
Planit recognises that making a disclosure as a whistleblower can be stressful. Planit will look at ways to provide support to the extent reasonably possible.
Planit will carry out separate training for eligible recipients within Planit on how to respond to protected disclosures.
This policy will be periodically reviewed (and, if necessary, amended) by Planit to ensure it is operating efficiently and complies with applicable legislation.
Name: Emma Pilcher
Title: Chief People & Culture Officer
Legal and Compliance Officer
Name: Devika Singh
Title: Legal & Compliance Officer