Whistleblower Policy
Maccabi Aquatics Whistleblower Policy
Purpose
This policy encourages individuals to report concerns about wrongdoing within Maccabi Aquatics, without fear of reprisal. Maccabi Aquatics values transparency and accountability and sees whistleblowing as a way to promote an ethical culture.
Scope
This policy applies to all Board and Committee members, staff, volunteers and individuals participating in Maccabi Aquatics programs including parents. This includes past and present employees, permanent, part-time, casual, contractors and suppliers of goods or services to Maccabi Aquatics, and associates of Maccabi Aquatics, including affiliated clubs and members. Relatives, dependents, or spouses of anyone in the above categories are also covered by this policy.
What is Whistleblowing?
Whistleblowing is the reporting of suspected illegal, improper, or unethical conduct occurring within Maccabi Aquatics. This can include:
- Illegal conduct (e.g., theft, drug offenses, violence)
- Fraud, money laundering, or misappropriation of funds
- Bribery
- Financial irregularities
- Breaches of legal or regulatory requirements
- Conduct that poses a risk to public safety or the stability of Maccabi Aquatics
- Detrimental conduct against someone who has made a disclosure
- Abuse of children and other persons in a sporting environment
- Failure to protect individuals in a sporting environment from bullying, intimidation, discrimination, or harassment
Who Can Report?
Anyone can make a report under this policy, including but not limited to those listed in the Scope section.
How to Report
To make a report, contact the Whistleblower Protection Officer (WPO) at wpo@maccabiaquatics.com.au. You can also report via phone or in person. You have the right to report anonymously.
The Role of the WPO
The WPO is responsible for:
- Receiving and managing whistleblower reports
- Protecting the confidentiality of reporters
- Investigating reports of wrongdoing
- Ensuring reporters are protected from retaliation
Confidentiality
Maccabi Aquatics is legally obligated to protect your identity if you make a report. Your identity will only be shared with those directly involved in managing and investigating your report, and only with your consent. This may include ASIC, APRA, or the Australian Federal Police. All directors of Maccabi Aquatics must keep the transactions and affairs of the company confidential, except as required by the Board, the company, the law, or to perform their duties.
Protection from Retaliation
Maccabi Aquatics prohibits any form of retaliation against individuals who make a report or who are believed to have made a report. This includes:
- Dismissal
- Demotion
- Harassment
- Intimidation
- Injury
- Damage to property or reputation
- Discrimination between them and other employees
- Enforcing any contractual or other remedy due to the investigation
Any person who takes or threatens to take reprisal against a whistleblower can face civil penalties. The Federal Court or Federal Circuit Court can also order significant civil remedies including:
- Compensation for loss, damage or injury
- Injunctions to prevent, stop or remedy the effect of reprisals or threats
- An order requiring an apology
- Reinstatement
- Exemplary damages
- Any other order the court thinks appropriate.
It is a criminal offense to harm or threaten to harm a whistleblower, punishable by up to 2 years in jail, a fine, or both.
Support for Reporters
Maccabi Aquatics will provide support to individuals who make a report. This may include:
- Counselling services
- Assistance in managing stress or performance impacts
- Help with lodging a complaint if you experience retaliation
Investigation Process
All reports will be taken seriously and investigated thoroughly. The investigation process will be fair, objective, and independent. Reporters will be kept informed of the progress and outcome of the investigation. All individuals involved in a whistleblower investigation will be treated fairly and provided with due process.
Policy Review
This policy will be reviewed periodically to ensure its effectiveness and compliance.
Related Policies and Legislation
This policy aligns with relevant legislation and organizational policies, including:
- Corporations Act 2001
- Tax Administration Act 1953
- Fair Work Act 2009
- Maccabi Aquatics Integrity Policy Framework
Version 1
December 2024