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1. Purpose

This policy ensures First Contact maintains a transparent, fair and legally compliant process for individuals to report suspected wrongdoing. It protects those who speak up in good faith from retaliation, and ensures concerns are handled confidentially and appropriately.

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2. Scope

This policy applies to:

• Current and former employees, contractors, consultants.
• Suppliers, service providers, board members and external stakeholders.

It covers disclosures involving:

• Corruption, fraud or theft.
• Harassment, bullying or discrimination.
• Bribery, conflicts of interest, or improper conduct.
• Modern slavery or human rights risks.
• Environmental or ESG breaches.
• Material violations of First Contact’s Code of Conduct or relevant laws.

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3. Legal Framework

This policy complies with:

• Corporations Act 2001 (Cth)  – Part 9.4AAA
• Tax Administration Act 1953 (Cth)
• ASIC Regulatory Guide 270
• Privacy Act 1988 (Cth)
• Modern Slavery Act 2018 (Cth)
• International ESG compliance frameworks (e.g. GRI, UNGC)

To receive legal protections, disclosures must be made to eligible recipients , including:

• Officers or senior managers of First Contact.
• The internal Governance & Risk team.
• First Contact’s external auditor or legal adviser.
• ASIC or other regulatory bodies.

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4. Whistleblower Protections

Eligible whistleblowers are legally protected from:

• Retaliation or dismissal.
• Threats or victimisation.
• Civil or criminal liability (for lawful disclosures).
• Breach of confidentiality.

All disclosures will be:

• Treated confidentially.
• Handled independently of any person named.
• Investigated fairly and promptly.

Whistleblowers will also be offered post-report welfare support , including access to EAP services.

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5. Reporting Channels

Internal:

• Head of Governance and Risk
• Managing Director.
• People & Culture (for HR-related matters).

Anonymous & External:

• Whistleblower Integrity Form  – [Insert secure link or tool].
• Regulatory Body – e.g. ASIC, ATO.

Reports can be made verbally or in writing , and may be anonymous.

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6. Investigation Process and Escalation

6.1 Initial Assessment:

All reports are triaged by Governance within 3 business days and assigned a materiality rating.

6.2 Escalation Matrix:

Where appropriate, disclosures may be logged in:

• The Enterprise Risk Register
• The ESG Compliance Dashboard
• The Board Risk Report

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7. Post-Disclosure Support and Fair Treatment

All whistleblowers:

• Will be treated respectfully and fairly
• Will not suffer retaliation or career disadvantage
• Will have access to independent EAP support services
• Will be offered a debrief (subject to confidentiality)

First Contact will take disciplinary action against any person found to have retaliated against a whistleblower.

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8. Responsibilities

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9. Review and Continuous Improvement

This policy will be reviewed annually, or earlier if:

• Laws or regulatory guidance changes
• A material whistleblower event occurs
• Required by the Executive or ESC

Reviews are managed by the Governance & Risk Team and submitted to the ESC for endorsement.

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10. Sign-Off

Author:
Governance & Strategy
Date: 2025-03-27

Policy Owner:
Helen Kostakos, Group Administration Manager ] Governance and Risk
Signature: ______________________

Approved by:
John Ortner, Managing Director
Signature: ______________________
Date Approved: 2025-03-27

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Whistleblower Protection

First Contact Pty Ltd

Integrity Starts With Speaking Up

At First Contact, we believe that a culture of trust is built on transparency. That’s why we support and protect anyone who chooses to speak up about misconduct, unethical behaviour, or serious wrongdoing.

Our Whistleblower Protection Policy  ensures every person — whether employee, contractor, client or supplier — can raise concerns safely and confidentially.

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What You Can Report

You can make a report about:

• Fraud, corruption or bribery.
• Bullying, harassment or discrimination.
• Modern slavery or unethical supplier conduct.
• Environmental or safety risks.
• Misuse of funds or breaches of our Code of Conduct.

If it doesn’t feel right — we want to know about it.

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How to Report a Concern

You can report concerns:

• Through our confidential Whistleblower Integrity Form.
• Directly to our Governance and Risk Team.
• Or to external regulators (ASIC, ATO) where applicable.

You can remain anonymous , and we’ll handle your report with care and discretion.

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You Are Protected

Everyone who makes a report in good faith is protected by:

• Confidentiality of identity.
• Protection from retaliation or dismissal.
• Access to support (including EAP services).
• Legal protections under Australian law.

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Governance That Listens

All reports are reviewed independently by our Governance Team and escalated when necessary to our Executive Steering Committee. We are committed to closing the loop with appropriate action, transparency and accountability.

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📄  View Our Full Policy

Read our [Whistleblower Protection Policy (PDF)] for more detail or contact the Governance Team via [Insert contact form or FC Hub link].

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Whistleblower Protection – Policy Snapshot

First Contact Pty Ltd

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Our Commitment

At First Contact, we foster a speak-up culture that protects integrity, transparency, and accountability. Our Whistleblower Protection Policy ensures that anyone who raises concerns about wrongdoing can do so safely, confidentially and without fear of retaliation.

We are committed to protecting whistleblowers and acting decisively on reports of misconduct.

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What You Can Report

Reports may relate to:

• Bribery, fraud, theft or corruption.
• Unsafe or unlawful practices.
• Harassment, bullying or discrimination.
• Modern slavery or human rights concerns.
• Environmental or ESG violations.
• Misuse of company resources.
• Breaches of law or First Contact policy.

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Who Can Make a Report

This policy applies to:

• Employees (current and former).
• Contractors, consultants and suppliers.
• Clients, board members and third-party stakeholders.

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How to Make a Report

Reports can be made:

• To a manager, the Governance & Risk team or MD.
• Via the secure Whistleblower Integrity Form (anonymous available).
• To external regulators such as ASIC or ATO  (where appropriate).

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Your Protections

Whistleblowers are protected under Australian law and First Contact policy:

• Confidentiality of identity and disclosure.
• Protection from dismissal, demotion or retaliation.
• Support services, including access to independent EAP
• Legal immunity for eligible disclosures made in good faith

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What Happens Next

• Every report is reviewed by our Governance Team.
• Serious matters are escalated to the Executive Steering Committee.
• Investigations are conducted independently, fairly and promptly.
• Outcomes are acted upon, and whistleblowers are supported throughout.

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Need More Information?

Refer to the full Whistleblower Protection Policy (FC-GOV-WHISTLE-001)
or contact the Governance & Risk team via [Insert internal/external contact form]