LEGAL

Whistleblowing Policy

KOSEC Group is committed to fostering a culture of transparency, integrity, and accountability. We encourage all current employees, officers, contractors, suppliers, and associates, as well as their relatives and dependents, to report any concerns regarding misconduct or improper activities within our organisation.

This Whistleblower Policy outlines the procedures for making such disclosures and the protections afforded to whistleblowers under Australian law.

1. Purpose

The objectives of this policy are to:

  • Encourage the reporting of suspected misconduct or improper activities.
  • Provide clear guidelines on how to make a disclosure.
  • Outline the protections available to whistleblowers.
  • Ensure disclosures are handled appropriately and confidentially.
  • Comply with the whistleblower provisions of the Corporations Act 2001 (Cth).

2. Scope

This policy applies to:

  • Current employees of KOSEC Group Pty Ltd.
  • Officers and associates.
  • Contractors, suppliers, and their employees.
  • Relatives, dependents, or spouses of the above individuals.

3. Reportable Conduct

Disclosures under this policy should be based on reasonable grounds and may relate to:

  • Illegal activities (e.g., theft, fraud, corruption).
  • Misconduct or improper state of affairs.
  • Breaches of KOSEC Group’s policies or code of conduct.
  • Conduct endangering health or safety.
  • Damage to the environment.
  • Victimisation or harassment of individuals.

4. Making a Disclosure

Disclosures can be made through a designated Whistleblower Protection Officer within KOSEC Group. Disclosures can be made anonymously, and all reasonable steps will be taken to protect the identity of the whistleblower.

5. Protection of Whistleblowers

KOSEC Group is committed to ensuring that whistleblowers are protected from any form of retaliation, discrimination, or detrimental action as a result of making a disclosure. This includes protection from:

  • Dismissal or demotion.
  • Harassment or intimidation.
  • Discrimination or bias.
  • Any other conduct that causes detriment.

Any breach of this policy will be taken seriously and may result in disciplinary action.

6. Handling and Investigating Disclosures

All disclosures will be handled promptly and confidentially. The process includes:

  • Receipt of Disclosure: Acknowledging the disclosure and assessing its nature.
  • Investigation: Conducting a thorough and objective investigation.
  • Outcome: Taking appropriate action based on the investigation’s findings.

Whistleblowers will be kept informed of the progress and outcome of the investigation, subject to confidentiality considerations.

7. Support and Fair Treatment

KOSEC Group will provide support to whistleblowers, which may include:

  • Access to counselling services.
  • Strategies to protect against detrimental conduct.
  • Assistance with managing stress or other challenges resulting from the disclosure.

8. Review and Accessibility of the Policy

This policy will be reviewed periodically to ensure its effectiveness and compliance with legal requirements. It will be made available to all employees and relevant stakeholders and can be accessed on the KOSEC Group intranet or upon request.

By adhering to this policy, KOSEC Group aims to promote a culture of openness and accountability, ensuring that concerns regarding misconduct can be raised and addressed appropriately.

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