Whistleblower policy

1.  Purpose 

The purposes of this policy are to ensure that The Sunrise Project Australia Limited (The Sunrise Project, Sunrise): 

  • promotes a culture of openness, transparency and accountability 
  • has effective procedures in place to support whistleblowers and  detect misconduct 
  • complies with its obligations as a public company under Part  9.4AAA of the Corporations Act 2001. 

2.  Scope 

This policy applies to all current and former Sunrise Board, members,  staff, contractors, secondees and volunteers and staff of partner organisations. All of these persons are able to make disclosures under  this policy. 

This policy forms part of the broader governance and compliance  measures within the Sunrise Project. 

3.  What should be reported 

We want to hear from you if you witness or know about any  misconduct, including behaviour which: 

  • is illegal 
  • is corrupt or an abuse of public trust 
  • is dishonest or fraudulent 
  • is unethical or contrary to Sunrise Project values 
  • endangers health and safety or the environment 
  • breaches any Sunrise Project policies or repeatedly breaches  administrative procedures 
  • is discrimination 
  • is harassment and/or bullying 
  • is detrimental to The Sunrise Project and could cause financial or  non-financial loss 
  • is maladministration (eg unjust, based on improper motives, is  unreasonable, oppressive or negligent).

From time to time you may have a complaint in relation to personal  work-related grievances or the behaviour of another person in the  organisation which is not misconduct. In that case, you should first  raise it with your manager or another senior colleague.  

4.  Where to report 

Sunrise staff and volunteers are encouraged to report their concerns  to their manager or another senior colleague. Where this is not  appropriate, alternative reporting mechanisms are available. 

External whistleblowers (such as staff of partner organisations) should  report their concerns to a senior member of Sunrise staff such as the  Operations Director, Deputy Director or Executive Director. Where this  is not appropriate, alternative reporting mechanisms are available. 

Alternative reporting channels are to be used when: 

  • the normal reporting channel is considered inappropriate 
  • senior management have been notified but have failed to deal with  it  
  • the whistleblower is concerned about possible retaliation. 

In any of these circumstances, the whistleblower may provide the  report to an eligible recipient such as: 

  • any Board member 
  • Auditor. 

All of the above persons are called “eligible recipients” under the  Corporations Act. Note that, under the Corporations Act, the Australian  Charities and Not-for-profits Commission (ACNC) is not an eligible  recipient. 

5.  How to report 

Reports can be made to individuals verbally or in writing through any  channel. 

See below for contact details. 

6.  Anonymity and confidentiality 

We respect and protect your identity if you choose to make an  anonymous report (eg by phone or post). You can choose to remain  anonymous while making a report, during investigation of your report,  as well as after your case is closed. At any time you can identify yourself,  but this is your choice and at no point do you need to do this nor will  you be forced to disclose your identity. 

If you decide to disclose your identity, your details and the information  you provide will be treated in strictest confidence by the recipient. We  will work to protect your identity and will outline and document who in  the organisation will know you submitted your report. We will also take all steps necessary (and outlined in this policy) to ensure you do not  suffer any retaliation. 

It is worth noting that while we will make every endeavour possible to  investigate your report, there may be limitations to what can be  achieved if you decide to remain anonymous. Correspondingly, we  cannot inform you of the progress or outcome of the investigation if we  do not know who you are.  

7.  The investigative process 

These are the steps we will go through to investigate a whistleblowing  report: 

  1. Report (anonymous or otherwise) is received. 
  2. A case manager is assigned to the report to assess it and confirm  receipt. This may be the recipient, another senior member of  Sunrise staff, a Board member or an external consultant with  specialist expertise relating to the report. 
  3. The case manager will do an initial assessment to confirm the  report is valid and will request permission from the whistleblower  to investigate. 
  4. The case manager will investigate the report. 
  5. When the investigation is complete, the case manager will  document the findings and inform the whistleblower,  management and the Board.  
  6. The case manager will then hand over all information to  management for any subsequent action. Information which could  be used to identify an anonymous whistleblower will not be shared  unless we are compelled to do so by law. 

8.  How we use third parties 

We may use specialist external parties such as auditors, investigators,  lawyers or HR consultants to conduct all or part of the investigation  where specialist expertise is required or where an internal investigation  would be inappropriate. 

We may also involve HR consultants or counsellors to ensure staff are  appropriately supported during an investigation and subsequent  action. 

9.  Who is alerted to a report 

When a reported is received, senior managers and the Board may be  informed by the recipient where that is appropriate. Any information  which could be used to identify an anonymous whistleblower will not  be shared unless we are compelled to do so by law. 

Note that where serious breaches of the law are alleged, we may be  legally obliged to report this to the relevant authorities, including the  police. In such instances we may be obliged to cooperate with them in their investigation, in which case it is possible that we may not be  permitted to shield your identity. We will still protect you from  retaliation if such a scenario eventuates. 

10.  How the whistleblower is informed 

As part of the investigative process, we will update you on the progress  of the investigation including: 

  • confirmation of receipt of the report 
  • that an investigation has commenced 
  • who has been notified of the report 
  • that the investigation is continuing 
  • that the investigation has been closed

We will update you at least once a month during an investigation. 

We will strive to provide as much feedback on the investigation as  possible. However, there may be information which cannot be shared  due to privacy requirements. 

11.  If the whistleblower is not satisfied with the  result 

If you are not satisfied with the result of our investigation, you have the  right to: 

  • ask for a review of the report and investigation by the Chair of the  Board 
  • where the investigation has been focused on the actions of the  Chair of the Board, you can request it be reviewed by another  member of the Board. 

If the Chair of the Board or the other Board member determines that  the investigation was concluded properly and no new information  exists that would change the result of the investigation, the  investigation will be concluded.  

12.  How whistleblowers are protected 

It is illegal to fire, harass or discriminate against a whistleblower or  potential whistleblower because they make a report. 

We will not tolerate any detriment inflicted on you, actual or  threatened, because of your report. Anyone found to be victimising or  disadvantaging another individual for making a report under this policy  will be disciplined and may be dismissed or referred to government  agencies for criminal or civil penalties. Other parties that have provided  witness statements or been involved in the investigation will also be  protected from retaliation. 

To this end, all records related to your report and the investigation will  be securely stored, with access to the information therein strictly limited to only those people directly involved in the process, as detailed  above in ‘The investigative process’. 

If you feel you are at risk of detriment because of your report, you  should immediately discuss this with the person to whom you have  reported initially. If that is not appropriate in the circumstances, you  should approach a member of the Board. 

With your consent, we may take other actions to provide you with  protection, such as putting you on leave or changing your role and the  people you work with. In addition, if anyone breaches your  confidentiality or causes detriment to you because of the report, that  person faces criminal or civil penalties. 

13.  False or malicious disclosure 

If you knowingly make a false or malicious report, you may be  disciplined. This discipline may consist of anything from a warning to  termination of employment, depending on the circumstances and any  legal considerations. Discipline is not the same as retaliation or  victimsation.  

As your employer, Sunrise is legally obliged to ensure you are protected  from retaliation and victimisation, and this obligation does not cease  even in the case of false or malicious disclosure.  

14.  Changes to this policy 

Any changes to this policy will be reviewed by and approved by the  Board. 

Any changes to this policy will be broadcast to all staff via email or  through the Slack communication channel.  

Document version information will be noted in the document  whenever changes are made. 

15.  Relevant legislation 

Corporations Act 2001 (Cth) Part 9.4AAA, and Regulatory Guide 270  “Whistleblower policies”.

Contact details 

The following contact details may be used to report: 

Position Name Email Phone
Co-Executive Director John  Hepburn[email protected] +61 407 231 172
Co-Executive Director Sam  La Rocca[email protected] +61 413 620 073
Global Chief of  OperationsNichola Gardner[email protected] +61  417 462 345
Company Secretary Emma  MacPheeemma.macphee@sunriseproject. org+61 431 088 309
Sunrise Admin  [email protected] +61 2 8057 5189
Chair of the Board Claire  Mallinson[email protected] +61 418 972 207
Chair of the Finance,  Risk, Audit and  Compliance Committee  (FRAC)Erna  de Vries[email protected] +61 418 692 402
Auditor, Stewart Brown  Chartered Accountants  [email protected] +61 294 123 033

By post: 

The Sunrise Project Australia Ltd 

Ground Floor, 17 Randle St 


The Sunrise Project

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