Whistle Blower Policy (1.F.4) 

1. Introduction 

1.1 Purpose and scope 

This policy applies to the Living School to ensure individuals who disclose wrongdoing in relation to the school can do so safely, securely and with confidence that they will be protected and supported. 

This policy will be published on the Living School website and made available to Guardians of Purpose (Board) members and employees. 

1.2 Related policies
Complaints or allegations of staff misconduct that do not meet the criteria of a whistleblowing disclosure will be addressed in accordance with the school’s Complaints Handling Policy and Procedures. 

1. Disclosures about reportable conduct will be addressed in accordance with the school’s Child Protection Policy. 
2. Disclosures regarding a grievance between staff members about work matters, including work  relationships and decision made by other staff members which impact on their work, may be addressed  in accordance with the school’s Staff Grievance Policy. 
3. Unlawful discrimination, harassment or bullying complaints may be addressed in accordance with the school’s Discrimination, Harassment and Bullying Statement. 

2. What is a qualifying disclosure? 

A qualifying disclosure is when an eligible whistleblower makes a disclosure to an eligible recipient, and the  eligible whistleblower has reasonable grounds to suspect that the information concerns a disclosable matter. 

A disclosure referred to in paragraph (1)(b) is authorised under this subsection if it: 

1. is made to ASIC; or 
2. is made to the Registrar*; or 
3. is made to APRA; or 
4. is made to a member of the Australian Federal Police (within the meaning of the Australian Federal Police Act 1979 ); or 
5. is made to a legal practitioner for the purpose of obtaining legal advice or legal representation in  relation to the operation of this Part; or 
6. is made to a person or body prescribed by the regulations for the purposes of this paragraph; or g) is made with the consent of the discloser.

3. Who can make a qualifying disclosure? 

3.1 Eligible whistleblowers

An eligible whistleblower is an individual who is or has been any of the following, in relation to the school: 

• a Guardian of Purpose member; 
• an employee; 
• a person who supplies goods or services (paid or unpaid); 
• an employee of a person who supplies goods or services (paid or unpaid); 
• an individual who is an associate of the School (as defined in the Corporations Act); and a relative or dependent (or dependents of a spouse) of any individual described above. 

3.2 Anonymous disclosures 

A disclosure can be made anonymously and still be protected under the Corporations Act. A discloser can  choose to remain anonymous while making a disclosure, over the course of the investigation and after the  investigation is finalised. 

However, this may make it difficult to investigate the reported matter. The school therefore encourages  disclosers to provide their names. 

If a discloser wishes to disclose anonymously, the discloser should provide sufficient information to allow the  matter to be properly investigated. The school encourages the discloser to provide an anonymous email  address through which additional questions can be asked and information provided. It will also allow the school  to report the progress of the investigation to the discloser, as appropriate. 

4. Disclosable matters that qualify for protection 

4.1 Disclosable matters 

A disclosable matter is a disclosure of information where the eligible whistleblower has reasonable grounds to  suspect that the information relating to the School or a related company concerns: 

misconduct; 

• an improper state of affairs or circumstances; 
• illegal activity (including conduct of officers and employees) – meaning activity in breach of the  Corporations Act or specified financial services legislation, or an offence against any law of the  Commonwealth punishable by imprisonment of 12 months or more; or 
• conduct (including conduct of officers and employees) that represents a danger to the public or financial  system. 

This may include any conduct in relation to the operation of the school that involves:

• fraudulent activity; 
• negligence; 
• unlawful or corrupt use of school funds; 
• breach of duty; 
• improper accounting or financial reporting practices; 
• systemic practices that pose a serious risk to the health and safety of any person on school premises or  during school activities. 

If a disclosure is not about a disclosable matter, it will not qualify for whistleblower protection under the Corporations Act. 

Review: January 2027