1. Application

This policy applies to all employees of the Iress group (together “Iress”) including agency workers, contractors or self-employed contractors. A copy of this policy is available on HQ, Iress' intranet.

2. Purpose

This policy details how people may report any instances they identify in the workplace which they have reasonable grounds to suspect represent inappropriate, unethical, illegal or fraudulent conduct (Reportable Conduct). The aims of this policy are:

a. to encourage people to report any suspected Reportable Conduct as soon as possible, with the knowledge that their concerns will be taken seriously, appropriately investigated, and that their confidentiality will be respected;

b. to provide people with guidance as to how to raise those concerns; and

c. to reassure people that they can raise any concerns and complaints of Reportable Conduct without fear of discrimination, intimidation, disadvantage or reprisal.

This policy does not form part of any contract of employment and does not create enforceable rights in a person’s favour. The policy can be amended or varied by Iress at any time.

3. Key elements

A ‘whistleblower’ is a person who raises a concern or complaint in relation to a matter which is inappropriate, unethical, illegal or fraudulent and may have a serious detrimental impact to him or herself, another employee of Iress, Iress itself, or a customer or shareholder of Iress. If a person has any reasonable grounds to suspect any Reportable Conduct, they should report it under this policy.

A person should report any of the following Reportable Conduct (this list is not exhaustive):

a. breach of an individual’s contract of employment;

b. breach of Health and Safety Regulations;

c. breach of other legal / regulatory obligations;

d. fraud of any kind including:

i.dishonesty and criminal behavior;

ii. the use of deception to obtain an unjust or illegal financial advantage; or

iii. intentional misrepresentation affecting the financial statements by one or more people among management, employees or third parties.

e. substantial damage or danger to the natural environment;

f. breach of Iress’ internal policies and procedures;

g. conduct likely to cause Iress financial loss or damage its reputation;

h. bribery;

i. harassment, discrimination, victimization or bullying, other than “personal work-related grievances”; or

j. the deliberate concealment of any of the above.

Grievances that are personal and work-related in nature should be addressed under Iress’ Grievance Policy or Anti-Harassment Policy, as appropriate.

If a person is uncertain whether something falls within the scope of this policy they should seek advice from their People Leader, the Legal team or the People@Iress team.

4. Raising a concern

In most cases, a person should be able to raise any concerns with their People Leader. Their People Leader may refer the matter to the Legal team or People@Iress team, if appropriate.

If the matter is serious or if the person would prefer not to raise it with their People Leader for any reason, they should contact either the Legal team or the People@Iress team.

The relevant team (the one that is contacted) will arrange a meeting with the whistleblower as soon as possible to discuss their concern. The whistleblower may bring a colleague to any meetings held under the auspices of this policy. Their companion must respect the confidentiality of the disclosure and any subsequent investigation.

Iress will take a written summary of the whistleblower’s concern and provide them with a copy after the meeting. Iress will also aim to give the whistleblower an indication of how Iress proposes to deal with the matter.

Iress recommends that people voice any suspected Reportable Conduct openly under this policy, but in the event that a whistleblower wishes to remain anonymous, they may raise their concerns through a letter to either their People Leader, the Legal team or the People@Iress team. The concern will not be treated any differently in the event that it is raised anonymously.

5. Confidentiality

Iress encourages cooperation from whistleblowers in order to ensure that a proper investigation can be undertaken. If it is considered useful for anyone investigating a whistleblower’s concern to know their identity, Iress will discuss this with them, and their consent will be sought prior to any disclosure. If a whistleblower is concerned about possible reprisals if their identity was to be disclosed, they should speak to the Legal team or the People@Iress team and appropriate measures can be taken to preserve confidentiality.

Notwithstanding the above, a whistleblower’s identity may be disclosed if one of the following exceptions applies:

a. they consent to the disclosure of their identity;

b. the whistleblowing concern is reported to Australian Securities and Investments Commission, the Australian Prudential Regulation Authority, the Tax Commissioner or the Australian Federal Police; or

c. the whistleblowing concern is raised with a lawyer for the purpose of obtaining legal advice.

6. External disclosures

The aim of this policy is to provide an internal mechanism for reporting whistleblowing concerns and therefore, in the majority of cases, a whistleblower should not find it necessary to alert anyone externally.

Under some circumstances, it may be appropriate for a person to report their concerns to an external body. Iress strongly encourages anyone who is in that situation, or suspects that they may be, to seek advice before reporting a concern to anyone external. It will rarely, if ever, be appropriate to alert the media or Parliament (as provided in the Treasury Laws Amendment (Enhancing Whistleblower Protections) Act 2019 (Cth)) directly, unless it is an “emergency” or “public interest” disclosure.

If a person’s concerns relate to the actions of a third party, Iress encourages them to report such concerns internally to their People Leader in the first instance, or the Legal team or the People@Iress team, as appropriate.

7. Investigation and outcome

Once a whistleblower has raised a concern, Iress will carry out an initial assessment to determine the scope of any investigation and will inform them of the outcome of this process. Iress may require further information to complete this assessment.

In some cases Iress may appoint an investigator (internal or external to Iress). Any investigation required will be conducted without regard to the whistleblower’s relationship to Iress, position or length of service.

Iress will aim to keep the whistleblower informed of the progress of the investigation and its likely timeline. However, sometimes the need for confidentiality may prevent Iress from giving them specific details of the investigation or any action taken as a result. The whistleblower should treat any information about the investigation as confidential.

If Iress concludes that a whistleblower has made false allegations maliciously, dishonestly or with a view to personal gain, the whistleblower will be subject to disciplinary action.

8. If a whistleblower is not satisfied

Iress cannot guarantee the outcome of the investigation, but Iress will deal with a whistleblower's concerns objectively, fairly and in an appropriate way. If a whistleblower is not happy with the way in which their concern has been handled, they can raise it with the Legal team or the People@Iress team or any of Iress’ parent company Directors, as appropriate.

9. Protection, support and fair treatment for whistleblowers and people involved

Iress aims to encourage openness and transparency throughout the whistleblowing process and will support people who raise whistleblowing concerns or complaints, on reasonable grounds, in relation to actual or suspected Reportable Conduct under this policy.

No person should suffer any detrimental treatment as a result of raising a concern or complaint pursuant to this policy. Detrimental treatment includes dismissal, disciplinary action, demotion, harassment, discrimination, bias, threats or other unfavourable treatment connected with raising a concern. If a person believes that they have suffered any such treatment, they should contact their People Leader, the Legal team or the People@Iress team immediately. If the matter is not remedied, they should raise it formally using the Grievance Policy.

People must not threaten or retaliate against whistleblowers in any way. Anyone involved in such conduct will be subject to disciplinary action.

All files and records created from an investigation into suspected Reportable Conduct will be retained securely. Unauthorised release of information contained within these investigation files and records without the whistleblower’s consent will be a breach of his policy and will be regarded as a serious matter and will be subject to Iress’ disciplinary procedure.