Whistleblower policy

INNOVATIVE MANUFACTURING CRC (ABN 24 607 527 499) (IMCRC) is committed to providing a healthy and safe working environment for its staff. The Whistleblower policy extends to all IMCRC staff, includig employees, board members, contractors, consultants, associates, and the relatives, dependants or spouses of IMCRC staff.

The purpose of this policy is to:

  • provide an understanding of what can be reported under this policy
  • demonstrate the importance IMCRC places on ensuring a safe and supportive environment where its staff are confident to raise breaches of internal rules or Disclosable Conduct
  • assist in creating a workplace culture that encourages staff to speak up about Disclosable Conduct
  • explain the processes for reporting Disclosable Conduct, including what happens when a report is made, and
  • to provide an outline how the protections are provided if a report is made.

This policy is not designed to circumvent the policies set out in IMCRC’s Staff Policies and Procedures Handbook.

What is Whistleblowing?

In general terms, a definition of whistleblowing is the disclosure by organisation members (former or current) of illegal, immoral or illegitimate practices under the control of their employers to persons that may be able to effect action. Whistleblowing concerns protecting people who act in the public interest when disclosing serious wrongdoing relating to issues or information regarding corruption, misconduct and maladministration.

Disclosable Conduct

Examples of Disclosable Conduct may include:

  • a breach of financial management
  • improper conduct including dishonesty, fraud, theft
  • bribery and corruption
  • providing false or misleading information
  • misuse of company resources
  • unauthorised payments
  • unethical behavior
  • unsafe work practice
  • breach of IMCRC Staff Policies and Procedures
  • victimisation, harassment or workplace bullying
  • discrimination (sex, age, gender, race, or religion)
  • contravention of Modern Slavery legislation

Disclosable Conduct is not:

  • a difference of opinion about a policy or procedure adopted by IMCRC in the Staff Policies and Procedures Handbook
  • a matter that relates to an employment dispute with IMCRC

Reporting Disclosable Conduct

Each staff member has a role and responsibility in ensuring IMCRC is run ethically and in accordance with IMCRC Staff Policies and Procedures. If you have any known or suspected concerns about unacceptable practices, misconduct, anything improper or the appropriateness of conduct, you should make a disclosure about it. Where an issue of Disclosable Conduct is identified, the matter should be raised as soon as possible with the people responsible for handling matters (refer below).


If an employee is concerned about making a report, the report should be made anonymously.

Who to report a matter to?

If reporting a suspicion of wrongdoing, first check with your designated manager or IMCRC’s CEO. If you do not wish to raise the matter with either your manager or the CEO, you should consider raising the matter with the Whistleblower Investigation Officer (WIO). If you do not feel safe to speak to any of the reporting channels noted above, and you wish to be protected by the organisation as a part of raising your matter, you can report your matter to the Whistleblower Protection Officer (WPO) as described in this policy.

The WIO is IMCRC’s representative responsible for receiving whistleblower disclosures of wrongdoing and overseeing its investigation and resolution. The WIO must (after reasonable assessment):

  1. appoint a WPO to provide support to the whistleblower
  2. be satisfied that action taken in response to the inquiry/investigation is appropriate to the circumstances, and
  3. ensure that all investigations are carried out in line with the principle of procedural fairness.

Disclosures should be made to people who are Eligible Recipients of such a disclosure, to ensure the discloser qualifies for protection. Eligible Recipients include officers or senior managers of IMCRC and persons authorised by IMCRC to receive disclosures, such as the WIO or the WPO. You are welcome to make a disclosure to any Eligible Recipient at any time.


Channel Contact Details
Whistleblower Investigation Officer (WIO):  Susie Reece Jones
FAL Lawyers
Whistleblower Protection Officer (WPO):


Kate Norton
IMCRC HR Consultant
Senior Manager (CEO): David Chuter
CEO and Managing Director


What happens

Should you report a Disclosable Conduct matter under this policy, you should provide as much factual information as possible, i.e: dates, times, location, individuals involved, witnesses, evidence, documents and any general information which may be helpful to assist IMCRC in determining what action may be required. IMCRC will consider the quality of the information that is reported. Any information provided may be used in an investigation or other appropriate action. All investigations will be conducted in a manner that is procedurally fair, confidential, conducted without bias and in a timely manner.

Examples of actions that IMCRC may take in response to an investigation may include:

  • a satisfactory explanation can be provided in relation to the matter
  • the matter is resolved by speaking to one or more parties
  • the matter is recorded and monitored going forward
  • a decision is made to investigate (internally or via independent, external investigators);
  • the matter is referred to an agency, or
  • a combination of the above.

If appropriate, you will be contacted and advised of what action will be undertaken by IMCRC. If an allegation is made in good faith, but is not confirmed by the investigation, no action will be taken against the person raising the misconduct concern.


In accordance with the Corporations Act, a whistleblower who qualifies for protection is entitled to:

  • protection of identity
  • protection from detrimental acts or omissions, such as dismissal or discrimination
  • compensation or other remedies if loss, damage, or injury is experienced
  • protection from civil, criminal and administrative liability.

IMCRC is committed to ensuring support and protection from reprisal if a matter is raised under this Whistleblower Policy. IMCRC will not tolerate retaliation against a whistleblower. IMCRC expects all staff to use this Whistleblower Policy appropriately and with honesty. Please note that IMCRC will not entertain allegations which are vexatious or frivolous and staff are not exempt from the consequences of their own misconduct.

Anonymous reports of alleged Disclosable Conduct are accepted, however, they may have limitations on an ability for IMCRC to undertake a proper investigation. Limitations may include an inability to provide feedback on the outcome and/or to gather additional particulars to assist an investigation.

Any breach of this policy may result in disciplinary action, including dismissal from IMCRC.

Availability of Policy

This policy is provided as part of the IMCRC Staff Policies and Procedures Handbook. It is also available on the IMCRC website. IMCRC staff are encouraged to make themselves familiar with the policy.


IMCRC’s Board is committed to this policy and its implementation and to ensuring an enjoyable, healthy and safe working environment.

Released on: 16th December 2019