Whistleblower Policy

Purpose

See Differently is committed to integrity, transparency, and accountability across all aspects of our work. We believe that staff, clients, participants, families, suppliers, and partners must feel safe to raise concerns about misconduct, risks, or unlawful behaviour. This policy establishes our Whistleblower System and ensures compliance with:

• Aged Care Act 2024 (including section 165 and associated Rules)
• NDIS Act 2013 and Code of Conduct
• Corporations Act 2001
• Fair Work Act 2009
• Child safety and working with children legislation
• Workplace Health and Safety (WHS) laws

By applying one integrated policy, See Differently ensures consistent protections across aged care, disability, children’s services, and corporate operations.

 

Scope

This policy applies to:

• Current and former employees, volunteers, contractors, and suppliers.
• Directors, executives, and governing persons.
• Clients, participants, children and young people in our care, their families, carers, and advocates.
• Associates or partner organisations engaged with See Differently.

A person making a disclosure under this policy is referred to as a whistleblower.

 

Person-Centred Approach at See Differently

When it comes to providing support to clients, See Differently is dedicated to a Person-Centred approach. Our philosophy, goal, and business strategy all revolve around Person-Centred support.

 

Reportable Conduct

Whistleblowers are encouraged to raise concerns where they reasonably believe there has been misconduct, improper behaviour, or a breach of law. Reportable conduct includes (but is not limited to):

• Abuse, neglect, or exploitation of aged care clients, NDIS participants, or children.
• Breaches of the Aged Care or NDIS Codes of Conduct, or relevant child safety standards.
• Fraud, theft, corruption, or misuse of funds.
• Breaches of privacy or confidentiality.
• Unsafe work practices or serious risks to health and safety.
• Discrimination, harassment, bullying, or victimisation.
• Breaches of workplace obligations under the Fair Work Act or WHS laws.
• Conduct that damages the reputation or integrity of See Differently.

Note: Personal employment grievances are generally managed under HR policies, unless they involve systemic issues, victimisation of a whistleblower, or risks to clients, participants, or children.

 

How to Make a Disclosure

Disclosures may be made through the following channels:

• Internal: Manager, Supervisor, or the Whistleblower Protection Officers (WPO) consisting of the People and Culture Business Partner and Quality, Risk and Compliance Team members.
• Confidential Website: seedifferently.relyplatform.com/home
• Hotline: 1300 790 228

 

External Reporting Channels:

• Aged Care Quality and Safety Commission: 1800 951 822
• NDIS Quality and Safeguards Commission: 1800 035 544
• Relevant state/territory child protection authority or Ombudsman
• ASIC or APRA
• Fair Work Ombudsman or WorkSafe regulator
• Police or other law enforcement

See Differently has partnered with Your Call to provide 24/7 external whistleblowing services. To use this service:

• Visit: Your Call – See Differently Program and click “make a report”.
• Call: 1300 790 228 (7am to midnight AEST on business days).

Reports may be made anonymously, and all disclosures will be treated confidentially.

 

Protections for Whistleblowers

See Differently prohibits retaliation of any kind, including victimisation, harassment, dismissal, demotion, discrimination, or disadvantage.

• Identity Protection: The identity of whistleblowers will be protected to the fullest extent permitted by law. Whistleblowers will be informed if disclosure is legally required.
• Immunity: Whistleblowers are protected from civil, criminal, or administrative liability for making a disclosure.
• Admissibility: Information disclosed is not admissible as evidence against the whistleblower in most legal proceedings (unless proven false).

 

Handling of Disclosures & Investigations

All disclosures will be handled promptly, fairly, and confidentially. The WPO or investigator will:

1. Acknowledge receipt within 2 business days (where contact is possible).
2. Assess if the disclosure falls under this policy and evaluate the risk of victimisation.
3. Decide if an investigation is required and appoint an independent investigator if necessary.
4. Conduct the investigation impartially using interviews and evidence review.
5. Prepare a report for the CEO (or the Board if the CEO is implicated).
6. Provide feedback to the whistleblower without breaching confidentiality.

 

Confidentiality Safeguards

• Use of gender-neutral language and redaction of personal details where possible.
• Access to records is limited strictly to investigation staff.
• Records are stored securely in digital and physical formats.
• Sensitive reports are not sent via shared emails or printers.

 

Training and Awareness

• All staff and volunteers receive induction and refresher training.
• Managers and investigators receive advanced training on handling disclosures.
• Monthly communications remind stakeholders that disclosures are welcome.
• Information is provided in plain English, Easy Read, and translated formats.

 

Governance and Review

Oversight rests with the Board to ensure compliance. This policy is reviewed annually or sooner if legislation changes. The Head of People and Culture monitors the effectiveness of the reporting processes.

 

Definitions

• Whistleblower: Any person who makes a disclosure under this policy.
• Victimisation: Conduct causing detriment to a whistleblower due to their disclosure.
• Detriment: Includes dismissal, demotion, harassment, reputational damage, or financial harm.
• Eligible Recipient: A person authorised by law or See Differently to receive disclosures.
• Whistleblower Protection Officer (WPO): Designated officer responsible for managing disclosures.

 

Commitment

See Differently is committed to a culture where people feel safe to speak up. Whistleblowing is essential for safeguarding rights and upholding the integrity of our services.