Background

The CPD Home Whistleblower Protection Policy is one of a number of policies and codes that promotes a culture of conducting the CPD Home business with honesty, fairness, and integrity.

Purpose

The aims of our policy are to:

• reinforce CPD Home and associated organisation’s commitment to identifying and responding to concerns and fostering a culture of continuous improvement
• encourage the reporting of suspected or actual wrongdoing
• provide guidance on how to raise concerns and how those concerns will be investigated
• reassure anyone who raises a concern that they can do so without fear of retaliation, even if they turn out to be mistaken).

Objective

To encourage and support those aware of or suspect a wrongdoing to report it, and to provide reassurance to those who do that CPD Home is committed to protecting their dignity, well-being, career, and good name.

Scope

This policy applies to:

• Doctorportal Learning Board members
• CPD Advisory Panel members
• all CPD Home staff, job candidates, student placements, trainees, contractors, subcontractors, volunteers and former employees
• subscribers and Certified Learning Providers
• a spouse, relative or dependant of any of the people listed above

CPD Home encourages anyone with knowledge or reasonable suspicion of reportable conduct to report it as soon as possible.

Definitions

Please refer to the Glossary for definition(s) of terms that apply to this policy.

Policy

Making a report
Whistleblowers when notifying of a reportable conduct are requested to provide as much information as possible and any known details about the events underlying the report (e.g., date, time, location, name of person(s) involved, possible witnesses to the events, evidence of the events (e.g., documents, emails) and steps they may have already taken to report the matter elsewhere or to try resolve the concern).

To help facilitate investigation of the reportable conduct, the whistleblower is encouraged to provide their name and a method for contacting them. This will enable the Whistleblower Investigation Officer to contact the whistleblower if they have any additional question and to update them on the progress of the investigation.

There is no requirement for a whistleblower to identify themselves for their disclosure to qualify for protection under the Corporations Act or the Taxation Administration Act. Anonymous reports will be treated as seriously as any other allegation, but investigations may be limited if the person making the report is unable or unwilling to be interviewed. Any whistleblower wishing to remain anonymous is encouraged to use an anonymous email address to facilitate communication regarding the investigation of the matter.

Our policy does not in any way restrict or diminish the right of any individual to make disclosures directly to relevant regulators.

Reporting channels

CPD Home has several reporting channels. Employees are encouraged to use normal business channels first for issues relating to their own personal circumstances (e.g., employment matters), or where normal business procedures exist (e.g., operational risk or compliance issues), except where a whistleblower believes they may suffer personal disadvantage or wish to use the protections under this policy.

Our policy establishes a dedicated whistleblowing channel in addition to those listed above. The alternate whistleblowing channel is to contact the Whistleblower Protection Officer.

Should either of the above be implicated directly or indirectly in the whistleblower’s intended report they should instead refer the matter to the Doctorportal Learning Board Chair.

Investigating reports

Investigations of reportable conduct will be conducted in a manner that is confidential, fair, and objective.

Confidentiality extends to all information received from whistleblowers. All information will be held securely and in strict confidence. All reports received through whistleblowing channels are assigned to a suitable Whistleblower Investigation Officer.

Whistleblower protection

CPD Home will not disclose the identity of or any information likely to identify the whistleblower unless:

• the whistleblower gives their consent
• the disclosure is required by law, or where CPD Home refers the matter to regulatory body, or
• the disclosure is necessary as part of the investigation process, including for the purposes of obtaining legal advice.

Whistleblowers will be protected from personal disadvantage or victimisation by CPD Home staff and/or decision makers, from having made a report. This protection extends to anyone else within or outside of the organisation who is assisting the investigation, as well as to the Whistleblower Investigation Officer.

CPD Home will not tolerate any retaliatory action against a whistleblower including:

• dismissal or termination of services
• demotion
• denial of access to services or processes to which they have a right
• any form of discrimination or harassment
• current or future bias or threats of any kind.

Any retaliatory action will be treated seriously and may be considered a serious misconduct resulting in disciplinary action, which may include termination of employment or position within CPD Home.

Note: This policy does not prevent the whistleblower being subject to:

• regular performance review or any reasonable management action, carried out in a reasonable manner, to manage their conduct or performance, or
• regular audit processes, if a CPD Home subscriber, or
• the consequences of any involvement in the reportable conduct disclosed.