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Whistleblower policy

Keystart recognises that whistleblowers may play an important role in identifying and calling out misconduct and harm to consumers. Read our policy here.

Whistleblower Policy – Version 1.11 – July 2022 

1. Defined terms

Capitalised terms used in this policy have the meanings given to them in section 14, unless the context requires otherwise.

2. Background to this policy

Keystart recognises that whistleblowers play an important role in identifying and speaking up about misconduct and harm to consumers, and the community.  

Keystart’s Whistleblower Policy is intended to foster an open and transparent culture of ethical practice and accountability, where Disclosers (including employees) feel comfortable to come forward to report on misconduct or wrongdoing within the organisation without reprisal. 

The Board of Directors and Executive Management encourage Disclosers that become aware of any misconduct or wrongdoing to speak up and undertake that Keystart will treat all such disclosures seriously and confidentially and will investigate them promptly and thoroughly.

Keystart believes that this policy is fundamental to good corporate governance and ethical business practices, complements our Code of Ethics and Conduct Policy, and supports our values of ‘Customer Focus, Agility, Teamwork and Integrity’.

3. Purpose

This policy’s objectives are to:

  • Encourage disclosure and reporting of any malpractice, misconduct or conflicts of interest at Keystart;
  • Protect and support Disclosers who report malpractice, misconduct or conflicts of interest, or any other Disclosable Matter at Keystart;
  • Set out the manner in which Keystart will manage whistleblowing reports;
  • Ensure that all reports are thoroughly investigated, and appropriate action taken; and
  • Meet Keystart’s legal and regulatory obligations1.

This policy will be made available to all officers and employees of Keystart via the intranet and on Keystart’s external website.

4. Who this policy applies to

This policy applies to Disclosers, who are all persons who are, or have been, any of the following:

  • An officer or employee (e.g. current and former employees who are permanent, part-time, fixed-term or temporary, interns, secondees, managers and directors);
  • A supplier of services or goods to Keystart (whether paid or unpaid) including their employees (e.g. current and former contractors, consultants, service providers and business partners);
  • An associate of Keystart; and
  • A relative, dependant or spouse of any person referred to above (e.g. relatives, dependants or spouse of current and former employees, contractors, consultants, service providers, suppliers and business partners).

A Discloser will qualify for protection under this policy, and the Act, if they have reported a Disclosable Matter, based on reasonable grounds:

  • To an Eligible Recipient;
  • To Your Call;
  • To ASIC, the ATO or Federal Police of Australia;
  • To a legal practitioner (at the cost of the Discloser) for the purposes of obtaining legal advice or legal representation about the operation of the whistleblower provisions under the Act; or
  • As a Public and Emergency Disclosure (it is important that they understand the criteria for a Public Emergency Disclosure and seek independent legal advice in relation to them before making one as specific rules apply).

5. Matters this policy applies to

A matter will be a Disclosable Matter if the Discloser has reasonable grounds to suspect that the disclosed information concerns, in relation to Keystart:

  • Dishonest, unethical, fraudulent or corrupt behaviour;
  • Offering or accepting a bribe;
  • A criminal offence;
  • A failure to comply with any legal or regulatory obligation;
  • A miscarriage of justice;
  • An act endangering the health and safety of any individual or damaging to the environment;
  • Unsafe work practices;
  • Financial impropriety including fraud, money laundering or misappropriation of funds;
  • Serious non-professional or non-ethical behaviour;
  • A failure to comply with Keystart’s policies and procedures;
  • Discrimination, vilification, sexual harassment, harassment, bullying and victimisation; 
  • A deliberate concealment of information relating to any of the above;
  • Other serious improper conduct (including gross mismanagement, serious and substantial waste of Keystart’s resources, or repeated breaches of administrative procedures); or
  • Any other conduct which may cause financial or non-financial loss to Keystart or be otherwise detrimental to the interests or reputation of Keystart, or any of its employees

whether or not it involves a contravention of law and whether it has occurred or is yet to occur.

A Discloser can still qualify for protection under this policy, and the Act, even if the Disclosable Matter turns out to be incorrect.

6. Matters this policy will not apply to

This policy does not apply to any disclosures of information that are not considered to be a Disclosable Matter, which includes disclosures relating to:

  • Poor performance of job duties; or
  • Personal work-related grievances.

Employees that have performance and work-related grievances may report them directly to their department manager or in accordance with Keystart’s grievance policy.

To avoid any doubt, a personal work-related grievance may still be considered a Disclosable Matter if:

  • It includes information about misconduct, or the information about misconduct includes or is accompanied by a personal work-related grievance (mixed report);
  • Keystart has engaged in conduct that represents a danger to the public;
  • The disclosure relates to information that suggests misconduct beyond the Discloser’s personal circumstances; or
  • The Discloser suffers from or is threatened with detriment for making a disclosure.

7. How to report a Disclosable Matter

A Discloser may report a Disclosable Matter at any time, to any Eligible Recipient. 

The role of the Eligible Recipient is to receive reports of Disclosable Matters. A list of Eligible Recipients can be found in section 14.

7.1. Disclosure options - Internal

A Discloser may report a Disclosable Matter to any Eligible Recipient, at any time.  

Disclosure options include:

  • By direct conversation with an Eligible Recipient;
  • By posting it as a letter addressed to an Eligible Recipient and marked as “Disclosable Matter - Confidential” to the following address:
Attn: Whistleblower Eligible Recipient 
PO Box 2016
Subiaco WA 6904; or
  • By emailing Keystart’s internal confidential whistleblower management email address at 2

7.2. Disclosure option - External

A Discloser may make a report using Keystart’s external whistleblowing service, Your Call. Your Call is an independent service provider that enables confidential reporting of whistleblower concerns. Reporting to Your Call allows a report to be made anonymously, if the Discloser chooses to do so.  A whistleblower report can be made to Your Call as follows:

  1. Online:
  2. A Discloser will be required to enter Keystart’s unique identifier code Keystart1989
  3. By phone using Your Call’s external reporting hotline: 1300 790 228 (9am to midnight AEST on business days).

How Your Call works

Your Call uses an online message board, which the Discloser will have access to after making the report. The message board allows them to:

  • Communicate with both Your Call and Keystart, with or without revealing their identity;
  • Securely upload any relevant documentation and/or material that they wish to provide;
  • Receive updates; and
  • Request support or report detriment.

If the Discloser’s report relates to an Eligible Recipient, Your Call will exclude that person from all communications when Your Call provides information about their report to Keystart. 

How to use Your Call if a Discloser has a speech or hearing impairment

If the Discloser is deaf or has a hearing or speech impairment, they can contact Your Call online. If they would like to contact Your Call by phone, they can do so through the National Relay Service. Simply choose the Your Call contact method at and request Your Call’s hotline 1300 790 228.

7.3. Disclosure to regulators and others

A report of a Disclosable Matter can also be made to:

Australian Securities Commission
GPO Box 9827

Brisbane QLD 4001; or

  • A legal practitioner (at the cost of the Discloser), for the purposes of obtaining legal advice or legal representation about the operation of the whistleblower provisions in the Act; or
  • A public interest or emergency disclosure can also be made to a journalist or a member of parliament in very limited circumstances. These circumstances are prescribed by legislation and a Discloser should seek independent legal advice (at their own cost) before considering making a public interest disclosure or an emergency disclosure. 

7.4. Disclosure to be made with reasonable grounds

To help preserve the integrity of this policy and its implementation, Disclosers should:

  • Ensure that the report of a Disclosable Matter is made with reasonable grounds. In practice, this means that there is more than just a suspicion and there is some information that supports the allegation, however a Discloser does not need to prove their allegation;
  • Ensure that, insofar as reasonably possible, they provide specific, adequate and pertinent information relating to the Disclosable Matter, including dates, places, names of persons and witnesses, amounts and other relevant information; and
  • Not discuss the Disclosable Matter with any person other than the Eligible Recipients.

In the event that an employee is found to have made a report of a Disclosable Matter that they should have reasonably known was false, malicious or for personal gain, such action will be regarded as misconduct and will be dealt with via Keystart’s relevant counselling and disciplinary policies.

8. Protections

To encourage potential Disclosers to share their knowledge and information of any misconduct or wrongdoing within Keystart, Disclosers will have the rights and protections set out in this policy, particularly under this section, and the Act. 

8.1. Anonymous disclosures

A Discloser may:

  • Choose to remain anonymous while making a disclosure, over the course of the investigation and after the investigation is finalised;
  • Refuse to answer questions that they feel could reveal their identity at any time, including during follow-up conversations; and
  • Choose to adopt a pseudonym for the purposes of making the report of the Disclosable Matter.

A Discloser will still be protected under this policy, and the Act, even if their Disclosable Matter remains anonymous, subject to the report of the Disclosable Matter being made in the manner provided for under section 7. 

Notwithstanding a Discloser’s rights to remain anonymous, please note that anonymity and the withholding of information from the Eligible Recipient may impede the quality and efficiency of an investigation.

Please also note that the Chief Executive Officer, Chief Risk Officer, Executive Manager Legal & Risk and Executive Manager of Organisational Capability may become involved in the conduct and management of a Disclosable Matter by virtue of their roles. The identity of the Discloser will not be disclosed to these people without the Discloser’s consent, but the substance of the report may be shared with them for the purpose of investigating and responding to the disclosure. If a Discloser does not want one or more of these persons involved, they should make this request to the Eligible Recipient, who will comply with that request.

8.2. Confidentiality

Keystart will take all reasonable steps to protect a Discloser’s identity by managing the disclosure on a ‘need to know’ basis and anonymising the Discloser’s identity during an investigation, and will not disclose:

  • That identity; or
  • Information that is likely to lead to the identification of the Discloser (which Keystart has obtained because the report of a Disclosable Matter was made),

except if Keystart’s disclosure is made to ASIC, a member of the Australian Federal Police, to a legal practitioner for the purpose of seeking advice on the whistleblower provisions of the Act or with the Discloser’s written consent (Exceptions).

Except for the Exceptions, it is illegal for a person to identify a Discloser or disclose information that is likely to lead to the Discloser’s identification. If they consider this has occurred, they may lodge a complaint with:

  • Keystart by emailing 3 ; or
  • ASIC via its online misconduct reporting tool or
  • YourCall as stipulated in section 7.3.

A person can disclose the information contained in a disclosure with or without the Discloser’s consent if:

  • The information does not include the Discloser’s identity;
  • The entity has taken all reasonable steps to reduce the risk that the Discloser will be identified from the information; and
  • It is necessary for investigating the issues raised in the disclosure.

8.3. Protection from detrimental acts

An employee, officer or contractor of Keystart must not engage in, or threaten, conduct that causes detriment to a Discloser (or another person) in relation to a Disclosable Matter because of that report of a Disclosable Matter being made.

Examples of detrimental conduct include, dismissal of an employee, alteration of an employee’s position or duties to their disadvantage and harassment or intimidation to a person, including psychological harm. 

To avoid doubt, the following do not constitute detrimental conduct:

  • Reasonable administrative action taken to protect the Discloser from detriment (e.g. moving the Discloser to a different working area and/or different work duties to prevent detriment); and
  • Managing a Discloser’s unsatisfactory work performance, where the action is in line with Keystart’s performance management framework and discipline policy.

8.4. Compensation and other remedies

A Discloser (or any other employee or person) can seek compensation and other remedies through the courts if:

  • They suffer loss, damage or injury because of the Discloser making a report of a Disclosable Matter; and
  • Keystart has failed to take reasonable precautions and exercise due diligence to prevent detrimental conduct.

Disclosers should seek independent legal advice in relation to any claims they wish to make in this regard.

8.5. Civil, criminal and administrative liability protection

A Discloser is protected, by virtue of and to the extent available under the Act, from any of the following in relation to a report of a Disclosable Matter that they make:

  • Civil liability (e.g. any legal action against the Discloser for breach of an employment contract, duty of confidentiality or another contractual obligation);
  • Criminal liability (e.g. attempted prosecution of the Discloser for unlawfully releasing information or other use of the Disclosable Matter against the Discloser in a prosecution (other than for making a false disclosure)); and
  • Administrative liability (e.g. disciplinary action for making the disclosure).

These protections do not grant immunity for any misconduct a Discloser has engaged in that is revealed in their report of a Disclosable Matter.

9. Handling and investigating a disclosure

9.1. Investigation procedures

After Keystart receives a disclosure from a Discloser, it will perform the following actions:

    1The Eligible Recipient who received a disclosure will assess if it is a Disclosable Matter (ie, qualifies for protection under this policy and the Act).1 week
    2If the disclosure is a Disclosable Matter, that Eligible Recipient will assess if a formal, in-depth investigation is required.2 weeks

    If an investigation is required, an investigation will be conducted by the relevant Eligible Recipients (refer to section 14) and a report prepared of the findings for the Chief Executive Officer or the Board of Directors, as appropriate.

    If the findings indicate that misconduct or wrongdoing has occurred, then the report must include recommendations to:

    a. Remedy any harm or loss that has arisen from the misconduct or wrongdoing (eg, disciplinary proceedings against the person responsible for the conduct and the referral of the matter to regulatory authorities); and

    b. Mitigate the future occurrence of the same or similar misconduct or wrongdoing.

    4 weeks
    4Implement recommendations, if any.Subject to nature of recommendations

Please note that estimated actions and timeframes may vary depending on the complexity and nature of the Disclosable Matter. Keystart will update Disclosers with any changes to estimated actions and timeframes. 

Keystart will provide Disclosers with regular updates in relation to an investigation of a Disclosable Matter. Typically, updates will be provided at the start, during and at the end of an investigation, however, the frequency and timeframes for updates will also depend on the complexity and nature of the Disclosable Matter.

9.2. Limitations to investigations

Disclosers need to be aware that Keystart may not be able to undertake a comprehensive investigation if it is not able to contact the Discloser (eg, if a report of a Disclosable Matter has been made anonymously and the Discloser has refused to provide, or has not provided, a means for Keystart to contact them). If a Discloser wants to be assured of anonymity, it is recommended that they make their disclosure using the Your Call service (see section 7.3) and maintain ongoing two-way communication via the Your Call platform. 

9.3. Reporting of findings

The Discloser’s identity will be anonymised in all reports and findings.

Reports will be documented in electronic format.

On receipt of a Disclosable Matter that is considered substantial, the Chair of the Board of Directors of Keystart will be informed of the matter, as appropriate (e.g. it will not be provided if doing so is likely to result in the Discloser being identified). 

Upon the completion of a report, the report will be:

  • Delivered to the Chief Executive Officer and the Board of Directors, as appropriate (e.g. it will not be provided to a person if doing so is likely to result in the Discloser being identified); and
  • Delivered to the Discloser, if requested by the Discloser and subject to the Discloser providing adequate contact details for this purpose.

It is important to note that the method for documenting and reporting findings will depend on the nature of the Disclosable Matter.

10. Fair treatment of individuals mentioned in a disclosure

Keystart will ensure fair treatment of its employees who are mentioned in a report of a Disclosable Matter by ensuring that:

  • Disclosable Matters will be handled confidentially, in accordance with this Whistleblower Policy;
  • The primary objective of any investigation into a Disclosable Matter is to determine whether there is enough evidence to substantiate or refute the matter(s) reported;
  • All investigations are undertaken in an objective, fair and independent manner;
  • An employee who is the subject of a report of a Disclosable Matter will be advised about the subject matter of the Disclosable Matter and given the opportunity to respond, as and when required by principles of natural justice and procedural fairness, and prior to any actions being taken; and
  • An employee who is the subject of a report of a Disclosable Matter is connected with third party support provider Relationships Australia.  Phone: 1300 364 277 or via their website:

11. Breach of this policy

Any breach of this policy must be reported to Risk & Compliance in line with Keystart’s Breach Reporting Policy. 

Depending on the severity of the breach there may be disciplinary action in line with Keystart’s Discipline Policy.

12. Approval

This policy has been approved by the Board.

13. Review, training, and further information in relation to this policy

This policy shall be reviewed biennially, or sooner if material changes are required, due to changes in legislation, standards or otherwise, by the Chief Risk Officer, with any material changes being presented by the Risk Committee to the Board of Directors for approval.

The Chief Risk Officer will be responsible for conducting upfront and ongoing education and training on the Whistleblower Policy, processes and procedures to all officers and employees. 

The Board (either directly or through the Audit Committee) will monitor the whistleblower management system to ensure that the broader trends, themes and/or emerging risks highlighted by the disclosures made under its policy are addressed and mitigated as part of its risk management and corporate governance.

If further information is required in relation to this policy, or on how to make a report of a Disclosable Matter, the contacts are Keystart’s Eligible Recipients as defined in section 14:

14. Definitions

Act means the Corporations Act 2001 (Cth).

ASIC means Australian Securities & Investments Commission.

ATO means Australian Taxation Office.

Associate has the meaning given to it in the Act.

Discloser has the meaning given to that term in section 4 of this policy.

Disclosable Matter has the meaning given to that term in section 5 of this policy. 

Eligible Recipients  means 

a) any C-suite or Executive Manager of Keystart. The following Eligible Recipients have additional training in handling Disclosable Matters and Keystart encourages Disclosers, where possible, to report a Disclosable Matter to them in the first instance :

i. Chief Risk Officer

ii. Executive Manager Legal & Risk

iii. Executive Manager Organisational Capability

If all three of the above managers are conflicted, and in any event:

iv. Chair of the Risk committee

b) an internal or external auditor (including a member of an audit team conducting an audit) - of  Keystart;

Public and Emergency Disclosures means ‘public interest disclosures’ or ‘emergency disclosures’ pursuant to section 1317AAD of the Act.

Your Call means the independent whistleblowing service procured to support Eligible Recipients handle any disclosures made against Keystart via multichannel options prescribed in this policy.


Including Part 9.4AAA of the Corporations Act 2001 (Cth) Protection for Whistleblowers & ASIC Regulatory Guide 270 – Whistleblower policies

A shared mailbox accessible only by the Eligible Recipients.

A shared mailbox accessible only by the Eligible Recipients.