Whistleblower Policy BOARD 53


The purpose of this policy is to:

  • Provide a framework for effectively report and investigating reportable conduct
  • Ensure our people feel confident about reporting reportable conduct and that they are protected against reprisals; and
  • Provide an alternative avenue for reporting matters that may cause loss or reputational damage to Hunter Primary Care


This policy applies to all Hunter Primary Care contractors and employees.

Policy Statement

Hunter Primary Care Limited (HPC) promotes a culture of corporate compliance and ethical behaviour and encourages the reporting of wrongdoing through the implementation of internal policies and procedures.

The Board and Senior Management of HPC encourage all staff and people associated with HPC to report Reportable Conduct. This includes employees and officers, contractors, suppliers, an individual who is an associate (as defined in Corporations Act) of the entity, and spouses and relatives of any of the above.  All people should feel confident about reporting without fear of reprisal. The Board and Senior Management is committed to protecting and supporting Whistleblowers where they act in good faith in reporting Reportable Conduct. At HPC, we give an undertaking to all Whistleblowers that we do not intend to take action against a Whistleblower for reporting. All reports will be kept confidential and secure.

1. The role of the Whistleblower Protection Officer

HPC has an appointed Whistleblower Protection Officer and this position is currently held by the Chief Executive Officer.  The Whistleblower Protection Officer can be contacted by:

The role of the Whistleblower Protection Officer is to safeguard the interests of the Whistleblower in accordance with this policy. The Whistleblower Protection Officer has direct, unfettered access to independent financial, legal and operational advisers as required and a direct line to the Board as required.

The Whistleblower Protection Officer is responsible for receiving and investigating the substance of reports. On the basis of sufficient evidence in support of matters raised in a report, the Whistleblower Protection Officer determines whether to refer reports for further action, or refute these where necessary. The Whistleblower Protection Officer is to ensure that the Whistleblower is kept informed of the outcomes of the investigation of his/her report, subject to the considerations of privacy of those against whom the allegations are made.

We aim to ensure all employees are continuously aware of who our Whistleblower Protection Officer is, and the alternative ways in which employees can contact him/her.

2. Whistleblower Protection

Any person who reports Reportable Conduct as defined by this policy must not be personally disadvantaged for having made the report by:

  • dismissal
  • demotion
  • any form of harassment
  • discrimination; or
  • current or future bias.

Any investigation undertaken will be conducted without bias and the person against whom the allegation is made should be given the right to respond.

The anonymity of the Whistleblower is protected by HPC. HPC acknowledges breach of this protection could result in fines as outlined in the Corporations Act Part 9.4AAA.

Where a Whistleblower has acted in good faith and has not him or herself engaged in serious misconduct or illegal conduct, they will be provided with immunity from disciplinary proceedings.

3. How and when does a Whistleblower make a report?

HPC has in place a Fair Treatment Procedure (HR13), which deals with how issues and concerns are dealt with internally within the work place. In the first instance, staff are encouraged to raise and resolve concerns using the procedures outlined in the Fair Treatment Procedure. However, the Fair Treatment Procedure may not be an adequate mechanism for reporting wrongdoing in all circumstances.

Any employee or contractor of HPC can make a Whistleblower complaint to the Whistleblower Protection Officer.

In the event the concern is about the Whistleblower Protection Officer, the report can be made confidentially to the Chair of the Board of Directors.

Reports can be made anonymously or confidentially. Anyone reporting this under policy must be acting in good faith and have reasonable grounds for believing that the information disclosed indicates a wrongdoing.

Reports of Reportable Conduct will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation and to the extent required/necessary to comply with the law.

4. Investigating reports

All investigations will be conducted in a manner that is confidential, fair and objective and affords natural justice to all people involved. The investigation process will vary depending on the nature of the conduct being investigated and the amount of information that has been provided in the report.

Where practicable, an update should be provided to the person who has raised the concern. Whistleblower reports will be promptly investigated and appropriate corrective action taken if warranted by the investigation.

The investigation will be conducted by the Whistleblower Protection Officer or by direction of the Chair or other person decided by the Board, depending on the particular circumstances and allegations. The investigation will not be conducted by a person who may be the subject of the investigation or has inappropriate links or connections (actual or perceived) to the person(s) or practice(s) under investigation.

The person conducting the investigation needs to ensure that:

  • They fully understand the allegation
  • They obtain any relevant written evidence
  • They contact & interview all the relevant parties
  • They record their findings
  • They prepare a report outlining their investigation, the conclusion they have reached and why they have reached this conclusion
  • Where appropriate, the report should be discussed with relevant parties prior to final submission to senior management or the Board.
  • The report should be tabled at a meeting with the appropriate Executive Manager, CEO or Board Committee; and
  • An audit trail should be maintained and critical findings and decisions made during the course of investigations documented

5. Unsubstantiated allegations 

Should a person purporting to be a Whistleblower makes a false report, or the report is unsubstantiated, made maliciously or knowingly false, such a matter will be taken seriously and disciplinary actions may be taken as provided for in the HPC internal policies and procedures (Fair Treatment Procedure HR 13, Inappropriate Behaviour HR 15, Performance Management HR 23 and Code of Conduct HR 67).

References/ Related Documents

  • Fair Treatment Procedure (HR 13)
  • Inappropriate Behaviour (HR 15)
  • Performance Management (HR 23)
  • Code of Conduct (HR 67)

Copies of these related documents can be requested by emailing whistleblower@hunterprimarycare.com.au


Whistleblower: A person who in good faith reports improper conduct through appropriate channels and may be at risk of reprisal for having made the report. A Whistleblower who reports, or seeks to make a report, will be given a guarantee of anonymity if this is desired by the Whistleblower. This provision is subject to circumstances in which the law requires the disclosure of the identity of the Whistleblower in legal proceedings.

 Reportable Conduct is conduct that in the view of the Whistleblower, acting in good faith, is:

  • dishonest
  • fraudulent
  • corrupt
  • illegal (including theft, violence or threatened violence, harassment, drug use and criminal damage against property);
  • in breach of Commonwealth or State legislation or local authority by-laws
  • unethical
  • other serious improper conduct
  • an unsafe work practice; or
  • any other conduct which may cause financial or non-financial loss to HPC or be otherwise detrimental to the interests of HPC.