Whistleblower Policy
Hatrix Recruitment is committed to the highest standards of conduct and ethical behaviour in all our business activities and to promoting and supporting a culture of honest and ethical behaviour, corporate compliance, and good corporate governance.
Hatrix Recruitment encourages the reporting of any instances of suspected unethical, illegal, fraudulent, or undesirable conduct involving Hatrix Recruitment and provides protections and measures so that those persons who make a report may do so confidentially and without fear of intimidation, disadvantage, or reprisal.
This Policy applies to all Officers, Managers and Employees of Hatrix Recruitment.
WHAT IS REPORTABLE CONDUCT?
You may make a report under this Policy if you have reasonable grounds to suspect that a Hatrix Recruitment Officer, Employee, Contractor, Supplier, or other person who has business dealings with Hatrix Recruitment has engaged in conduct (Reportable Conduct) which:
- Is dishonest, fraudulent, or corrupt, including bribery.
- Is illegal activity (such as theft, violence, harassment or intimidation, criminal damage to property or other breaches of state or federal law).
- Is unethical or in breach of Hatrix Recruitment Policies (such as dishonestly altering Company records or data, adopting questionable accounting practices or wilfully breaching Hatrix Recruitment Code of Conduct or other Policies or Procedures).
- Is potentially damaging to Hatrix Recruitment, a Hatrix Recruitment Employee or a third party, such as unsafe work practices, environmental damage, health risks or abuse of Hatrix Recruitment property or resources.
- Amounts to an abuse of authority.
- May cause financial loss to Hatrix Recruitment or damage its reputation or be otherwise detrimental to Hatrix Recruitment’s interests.
- Involves harassment, discrimination, victimisation, or bullying, other than personal work-related grievances as defined in the Corporations Act 2001 (Cth) (Corporations Act).
- Involves any other kind of misconduct or an improper situation or circumstances.
WHO CAN I MAKE A REPORT TO?
Hatrix Recruitment has several channels for making a report if you become aware of any issue or behaviour which you consider to be Reportable Conduct. For the purposes of this Policy to ensure appropriate escalation and timely investigation, we request that reports are made to the Protected Disclosure Officers, listed below:
Elizabeth Platt
Operations Manager
Hatrix Recruitment
(07) 2141 6888
Level 2, 3350 Pacific Highway, Springwood QLD 4127
While it is Hatrix Recruitment’s preference that you raise reports with the Protected Disclosure Officers, it is important to note that under the Corporations Act, you may also raise the matter with an Officer or Senior Manager of the Company. These are defined in the Corporations Act as an Officer or a Senior Manager in the Company who makes, or participates in making, decisions that affect the whole, or a substantial part, of the business of the Company, or who has the capacity to significantly affect the Company’s financial standing.
INVESTIGATION OF REPORTABLE CONDUCT
Hatrix Recruitment will investigate all matters reported under this Policy as soon as practicable after the matter has been reported. A Protected Disclosure Officer may, with your consent, appoint a person to assist in the investigation of a report. Where appropriate, Hatrix Recruitment will provide feedback to you regarding the investigation’s progress and/or outcome (subject to considerations of the privacy of those against whom allegations are made). The investigation will be conducted in an objective and fair manner, and otherwise as is reasonable and appropriate having regard to the nature of the reportable conduct and the circumstances.
While the investigation process and enquiries adopted will be determined by the nature and substance of the report, in general, as soon as practicable upon receipt of the report, if the report is not anonymous, a Protected Disclosure Officer or investigator will contact you to discuss the investigation process including who may be contacted and such other matters as are relevant to the investigation. Where a report is submitted anonymously, Hatrix Recruitment will conduct the investigation and its enquiries based on the information provided to it.
PROTECTION OF WHISTLEBLOWERS
Hatrix Recruitment is committed to ensuring confidentiality in respect of all matters raised under this Policy, and that those who make a report are treated fairly and do not suffer detriment.
A. Protection against detrimental conduct.
- Detrimental treatment includes dismissal, demotion, harassment, discrimination, disciplinary action, bias, threats, or other unfavourable treatment connected with making a report.
- If you are subjected to detrimental treatment because of making a report under this Policy, you should inform a Protected Disclosure Officer, Officer, or Senior Manager immediately under this Whistleblower Policy
B. Protection of your identity and confidentiality.
- Subject to compliance with legal requirements, upon receiving a report under this Policy, Hatrix Recruitment will only share your identity as a whistle-blower or information likely to reveal your identity if:
i. You consent.
ii. The concern is reported to the Australian Securities and Investments Commission(ASIC),
the Australian Prudential Regulation Authority (APRA), the Tax Commissioner or the
Australian Federal Police (AFP).
iii. The concern is raised with a lawyer for the purpose of obtaining legal advice or
representation.
- If Hatrix Recruitment needs to investigate a report, it may disclose information that could lead to your identification, but it will take reasonable steps to reduce this risk. Any disclosures of your identity or information likely to reveal your identity will be made on a strictly confidential basis.
C. Protection of files and records.
- All files and records created from an investigation will be retained securely. Unauthorised release of information to someone not involved in the investigation (other than Senior Managers or Officers who need to know to take appropriate action, or for corporate governance purposes) without your consent as a whistle-blower will be a breach of this Policy.
- Whistle-blowers are assured that a release of information in breach of this Policy will be regarded as a serious matter and will be dealt with under Hatrix Recruitment Disciplinary Procedures.
DUTIES OF EMPLOYEES IN RELATION TO REPORTABLE CONDUCT
It is expected that Employees of Hatrix Recruitment who become aware of actual, or suspect on reasonable grounds, potential cases of reportable conduct will make a report under this Policy or under other applicable Policies.
GROUP REPORTING PROCEDURES
Protected Disclosure Officers (as appropriate) will report to the Employer on the number and type of whistleblower incident reports annually, to enable Hatrix Recruitment to address any issues at a group level. These reports will be made on a ‘no names’ basis, maintaining the confidentiality of matters raised under this Policy.
