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Whistleblowing Policy


UFS Pharmacies is committed to the highest standards of conduct and ethical behaviour in all of our business activities, and to promoting and supporting a culture of honest and ethical behaviour, corporate compliance and good corporate governance.

Employees are expected to co-operate with the organisation in maintaining legal, proper and ethical operations, if necessary by reporting non-compliant actions by other people.

UFS Pharmacies encourages the reporting of any instances of suspected unethical, illegal, fraudulent or undesirable conduct involving our organisation, and will ensure that those persons who make a report shall do so without fear of intimidation, disadvantage or reprisal.

The purpose of this policy is to:

  • encourage the reporting of matters that may cause harm to individuals or financial on non-financial loss to UFS Pharmacies or damage to the organisation’s reputation;
  • enable UFS Pharmacies to deal with reports from whistleblower in a way that will protect the identity of the whistleblower as far as possible and for the secure storage of the information provided;
  • establish policies for protecting whistleblowers against reprisal by any person, internal or external, to the organisation;
  • help to ensure that UFS Pharmacies maintains the highest standards of ethical behavour and integrity.


The UFS Pharmacies’ Board of Directors is responsible for adopting the whistleblower policy, and for nominating the Whistleblower Protection Officer (WPO).

The WPO is responsible for:

  • co-ordinating an investigation into any report received from a whistleblower, and
  • documenting and handling all matters in relation to the report and investigation, and
  • finalising all investigations.

The organisation’s CEO is responsible for the implementation of the whistleblower policy.

All staff and all volunteers are responsible for reporting breaches of general law, organisational policy, or generally recognised principles of ethics to a person authorised to take action on such breaches.


Whistleblower – person (being a director, manager, employee, contractor, volunteer of UFS Pharmacies who, whether anonymously or not, makes, attempts to make or wishes to make a report in connection with reportable conduct and wishes to avail themselves of protection against reprisal for having made the report.

Reportable conduct – includes, but is not limited to, the following: 

  • behaviour which is dishonest, fraudulent or corrupt, including bribery, misappropriation of funds and money laundering;
  • illegal activity such as theft, drug sale or use, violence or threatened violence, harassment or intimidation, criminal damage to property or other breaches of or failure to comply with state or federal law;
  • behaviour which is unethical or in breach of UFS Pharmacies’ policies;
  • behaviour which is potentially damaging to UFS Pharmacies, a UFS Pharmacies’ employee or a third party, such as unsafe work practices, environmental damage, health risks or abuse of UFS Pharmacies property or resources;
  • behaviour which amounts to an abuse of authority;
  • behaviour which may cause financial loss to UFS Pharmacies or damage its reputation or be otherwise detrimental to the orgnaisation’s interests;
  • behaviour which involves harassment, discrimination, victimisation or bullying; 
  • engaging in, or threatening to engage in detrimental conduct against a person who has made a disclsure or is believed or suspected to have made, or be planning to make, a disclosure;or
  • behaviour which involves any other kind of serious impropriety.

Breaches of general law, organisational policy or generally recognised principles of ethics – include, but is not limited to, the following:

  • corrupt conduct;
  • fraud or theft;
  • official misconduct;
  • maladministration;
  • harrassment or unlawful discrimination;
  • serious and substantial waste of public resources;
  • practices endangering the health or safety of staff, volunteers or the general public;
  • practices endangering the environment.

Complaints regarding work health and safety should, where possible, be made through the organisation’s work health and safety procedures.

Personal work-related grievances

Disclosures that relate solely to personal work-related grievances, and that do not relate to detriment or threat to the discloser, do not qualify for protection under this policy.

Personal work-related grievances are those that relate to the discloser’s current or former employment and have, or tend to have, implications for the discloser personally, but do not have any other significant implications for the organisation (or another organisation) or relate to any reportable conduct, or alleged conduct, relating to an organisation.


Where an employee of UFS Pharmacies believes in good faith on reasonable grounds that any other employee, director, officer, volunteer, contractor, supplier, tenderer or other person who has dealings with the organisation has engaged in reportable conduct, breached any provision of the general law or the organisation’s constitution, policies or code of conduct that employee must report their concerns to:

  • their supervisor; or, if they feel that their supervisor may be complicit in the breach,
  • the CEO; or, if they feel that the CEO may be complicit in the breach,
  • a director; or
  • the organisation’s Whistleblower Protection Officer (WPO); or, if they feel this to be necessary,
  • a person or office independent of the organisation nominated by the organisation to receive such information, or
  • the duly constituted authorities responsible for the enforcement of the law in the relevant area.

Disclosures may be made anonymously, and this anonymity shall, as far as possible, be preserved by the organisation.

A report should be made in writing, where possible, and should contain, as appropriate, details of:

  • the nature of the alleged reportable conduct;
  • the person or persons involved in the reportable conduct;
  • the facts on which the reportee’s belief that reportable conduct has occurred, and has been comiitted by the person or persons named, are based;
  • the nature and whereabouts of any further evidence that would substanitate the reportee’s allegations, if known.

Evidence to support the reportee’s concerns should be produced at the time of reporting if it exists. The absence of such evidence will be taken into account in subsequent consideration of whether to open an investigation into the matter. However, absence of such evidence is not an absolute bar to the activation of the organisation’s investigation procedures. The existence of the reportee’s concern is sufficient to trigger reporting responsibilities.

Disclosures made to a legal practitioner for the purposes of obtaining legal advice or legal representation are protected in relation to the operation of the whistleblower provisions of the Corporations Act, even in the event that the legal practitioner concludes that a disclosure does not related to a reportable matter.

Any employee making a disclosure who informs commercial media or utilises social media or any other means of communication to raise their concern, will not be protected under this policy, unless it is not feasible for employees to report internally or existing reporting channels have failed to deal with the issues effectively.

Making a disclosure of reportable conduct does not necessarily absolve the reportee of any involvement on their own part in the reportable conduct.


UFS Pharmacies will investigate all matters reported under this policy as soon as possible after the matter has been reported.

If the person to whom a report has been made believes that the behaviour complained of is unquestionably trivial or fanciful the allegation will be dismissed and the reportee advised in this regard.

If the behaviour reported is considered neither trivial nor fanciful, the person to whom a disclosure regarding reportable conduct is made shall notify the CEO, who shall be reponsible for ensuring that an investigation of the charges is established and adequately resourced. If the reportable conduct relates to the CEO a director of the organisation shall be notified.

Terms of reference for the investigation will be developed, in consultation with the CEO (or the Board if the reportable conduct relates to the CEO), to clarify the key issues to be investigated.

An investigation plan will be developed to ensure all relevant questions are addressed, the scale of the investigation is in proportion to the seriousness of the allocations(s) and sufficient resources are allocated.

Strict security will be maintained during the investigative process and all information obtained will be properly secured to prevent unauthorised access. All relevant witnesses will be interviewed and, where possible, interviews will be taped. Contemporaneous notes of all discussions, including via telephone and other means of techology will be made and all relevant documentation will be examined.

All investigations will be conducted in an objective and fair manner and shall observe the rules of natural justice and the provisions of procedural fairness, having regard to the nature of the reportable conduct and the individual circumstances.Where an adverse comment about a person is likely to be included in a report, the person affected will be given the opportunity to comment beforehand and any comments will be considered before the report is finalised.

Subject to the whistleblower’s consent a person may be appointed by the organisation to assist in the investigation of a matter raised in a report.  Where appropriate, UFS Pharmacies will provide feedback to the whistleblower regarding the investigation’s process and/or outcome (subject to considerations of privacy).


A report will be prepared when an investigation is complete and will include:

  • the allegations;
  • a statement of all relevant findings of fact and the evidence relied upon in reaching any conclusions.
  • the conclusions reached and the basis, including the damage caused, if any, and the impact on the organisation and other affected parties;
  • recommendations based on the conclusions to address any wrongdoing identified and any other matters arising during the investigation.

Subject to privacy considerations against whom the allegations are made and customary practices of confidentiality, the whistleblower will be kept informed of relevant progress of the investigation and its relevant outcomes.

Protection of Whistleblowers

UFS Pharmacies is committed to ensuring confidentiality in respect of all matters raised under this policy. Any person making a report in good faith will not suffer any sanctions from the organisation on account of their disclosure provided that their actions are based on reasonable grounds and conform to the relevant procedures. UFS Pharmacies will ensure that whistleblowers are treated fairly and do not suffer any disadvantage including in the event that the disclosure turns out to be incorrect.

Protection of identity and confidentiality

Subject to compliance with legal requirements, upon receiving a report under this Policy, UFS Pharmaies will not, nor will any member of the organisation, disclose any particulars that would suggest or reveal a reportees’ identity as a whistleblower, without first obtaining consent to do so.

Any disclosure that you consent to will be made on a strictly confidential basis. However, the organisation is able to disclose the complaint without your consent to the Australian Securities and Investments Commission (ASIC), the Australian Prudential Regulation Autority (APRA) or the Australian Federal Police.

Reportees should be aware that the maintenance of anonymity may make the alleged breach difficult to substantiate in any subsequent investigation.

Where anonymity is requested reportees are required to maintain confidentiality regarding the issue on their own account and to refrain from discussin the matter with any unauthorised persons.

Protection of files and records

All files and records created from an investigation will be retained under strict security and unauthorised release of information to someone not involved in the investigation (other than senior managers or directors who need to know to take appropriate action, or for corporate governance purposes) without the consent of the whistleblower will be a breach of this policy.

Whistleblowers 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 the organisation’s disciplinary procedures.


The CEO will designate an officer of the organisation to be responsible for ensuring that whistleblowers who make a report in good faith on reasonable ground suffer no employment-related disadvantage on account of their actions and to provide additional support for the reportee where necessary. Detrimental employment-related treatment includes dismissal, demotion, harassment, discrimination, disciplinary action, bias, threats or other unfavourable treatment connected with making a report. 

Duties of employees in relation to reportable conduct

All staff and all volunteers are expected to make a report under this policy where they become aware of known, suspected or potential cases of reportable conduct. This includes, but is not limited to, reporting breaches of general law, organisational policy, or generally recognised principles of ethics to a person authorised under this policy to take action on such breaches.

The Board of UFS Pharmacies will be informed as soon as possible by senior management of a report once received.

Policy dissemination

This policy forms part of the UFS Pharmacies policies and procedures and is available to staff in the staff handbook located on Confluence. This policy is also available on the organisation’s website at www.bendigoufs.com.au.