Whistleblower Policy
The Organisation (Community Culture Ltd and its subsidiaries; Great Community Transport t/a Active Care Network and Peppercorn Services Inc.) is committed to an ethical, fair and safe environment where people can speak up about concerns. You can report suspected wrongdoing confidentially—and anonymously if you wish. We do not tolerate retaliation against anyone who reports on reasonable grounds.
Full policy access: Our complete Whistleblower Policy (PAP-GOV-006) is available to officers and employees on the intranet or on request at governance@communityculture.org.au. This page is a plain-English summary tailored for staff, clients, families, carers, volunteers and suppliers.
Who can report (you’re covered)
• Current or former employees, volunteers, students, contractors, suppliers, tenderers and board directors
• Spouses, relatives or dependants of any of the above
• Participants, families, carers and authorised representatives
You’re protected when you make a report on reasonable grounds (you don’t need proof—well-founded suspicion is enough).
What to report (qualifying disclosures with examples)
Report any suspected:
• Fraud / financial misconduct (e.g., false invoices, misappropriation, kickbacks, insolvent trading, tax misconduct)
• Bribery/corruption, conflicts not declared, supplier collusion
• Criminal conduct (e.g., theft, drug dealing at work, wilful property damage)
• Serious risks to health/safety or the environment
• Breaches of law, regulation or policy (e.g., privacy breaches, record falsification)
• NDIS: breaches of the NDIS Code of Conduct/Practice Standards; failure to record/respond to NDIS reportable incidents
• Aged Care: SIRS reportable incidents (e.g., unreasonable use of force, unlawful sexual contact, unexplained absence)
• Child safety: abuse, grooming, neglect; breaches of NSW Child Safe Standards
• Victimisation or threats against someone who made, or may make, a report
Not usually qualifying: pay disputes, rosters, performance ratings, interpersonal conflict (these go to Grievance).
However: Any concern about participant/client or child safety (including suspected abuse/neglect) is a qualifying disclosure.
How to report (choose what suits you)
• Internal (Community Culture)
• Whistleblower Protection Officer (WPO)
Rob Ewin – President of Board (via reception)
Phone: 1300 646 444 (ask for the WPO)
Email (optional): governance@communityculture.org.au (you may use a non-identifying email)
• Independent External Whistleblower Service
SDJA – Scott Carey: 0477 927 508
You can report anonymously (pseudonym or non-identifying email).
Interpreter support: Call TIS National 131 450 and ask for 1300 646 444.
Direct to regulators (you remain protected)
• Aged Care Quality & Safety Commission: 1800 951 822 – agedcarequality.gov.au
• NDIS Quality & Safeguards Commission: 1800 035 544 – ndiscommission.gov.au
• NSW Office of the Children’s Guardian (OCG): (02) 8219 3600 – ocg.nsw.gov.au
• NSW DCJ – Child Protection Helpline: 132 111 (24/7)
• ASIC (corporate misconduct): asic.gov.au
• ATO (tax whistleblowing): ato.gov.au
• NSW Police for criminal conduct
Legal advice: You can seek confidential legal advice from a lawyer—this is protected.
What to include in your report (helps us act quickly)
• What happened, who was involved, where/when it occurred
• Any harm or risk (to people, participants, children, the public, finances, environment)
• Any evidence you hold (documents, emails, dates, screenshots)—do not break laws to obtain it
• Whether you fear retaliation or need immediate safety measures
• How we can contact you (or specify you wish to remain anonymous)
If you want to stay anonymous (practical tips)
• Use a personal device and non-identifying email/pseudonym
• Avoid metadata that reveals identity/location (e.g., shared office scanners)
• Tell us your preferred secure contact method (e.g., new email only for this matter)
• You may decline to answer any question that could reveal your identity
What happens next (our process and timelines)
1. Acknowledge receipt within 7 days (if contact is possible).
2. Initial assessment (risk, eligibility, mandatory reporting needs) within 14–21 days.
3. Safety planning (if needed): protective steps to prevent detriment/retaliation.
4. Mandatory notifications (if required):
o Aged Care SIRS: notify the Aged Care Commission in line with SIRS timeframes (e.g., Priority 1 incidents ASAP/within 24 hours).
o NDIS: notify the NDIS Commission for serious incidents within 24 hours; other reportables generally within 5 business days.
o Child Safety: report to OCG/DCJ/Police as soon as practicable.
5. Investigation decision & scope: internal or external investigator; terms of reference set by the WPO.
6. Investigation (objective and fair): collect documents, interview relevant people, keep secure notes and evidence.
7. Outcome & actions: findings, corrective/remedial steps; de-identified governance reporting to the Board.
8. Updates: periodic updates where practicable and lawful (regulator processes may affect what we can share).
If a regulator (Aged Care Commission, NDIS Commission, OCG, Police) is investigating, we may sequence, limit or pause internal steps to avoid interference, while preserving evidence and protections.
Your protections (no retaliation)
If you report on reasonable grounds in line with our policy:
• Your identity is confidential (or you can remain anonymous)
• You are protected from civil, criminal and administrative liability for making the disclosure (this doesn’t excuse your own misconduct)
• We prohibit dismissal, demotion, harassment, discrimination, threats or other detriment because you reported
• You may have rights under the Fair Work Act 2009 (adverse action) and can seek compensation if harmed due to your disclosure
• Witnesses and people who assist an investigation receive the same protections
False or malicious reports may result in appropriate action. Good-faith reports are protected even if not substantiated.
Special pathways (Aged Care, NDIS, Child Safety)
This whistleblower channel does not replace required incident/reporting pathways:
• Aged Care SIRS reportable incidents
• NDIS reportable incidents
• Child Safety / Reportable Conduct and mandatory reporting
If your concern indicates any of the above, the WPO ensures mandatory notifications and coordinates any parallel investigations.
Public Interest & Emergency Disclosures (Corporations Act)
In limited circumstances, you may disclose to a journalist or parliamentarian and remain protected—but strict legal conditions apply, including (summary only):
• You previously reported to ASIC/APRA or a prescribed body;
• 90 days have passed and you reasonably believe no action is being taken (Public Interest Disclosure); or
• There is a substantial and imminent danger to health/safety/environment (Emergency Disclosure); and
• You gave us written notice identifying the prior disclosure and stating your intention to make a Public Interest/Emergency Disclosure; and
• You disclose no more information than necessary.
If you’re unsure, please seek independent legal advice before using these pathways.
Privacy and Collection Notice
We collect and use information in order to receive, assess, investigate and respond to disclosures; meet legal/reporting obligations (including Aged Care SIRS, NDIS and Child Safety); manage risks; and implement remedial actions.
• Handled under the Privacy Act 1988 (APPs) and NSW PPIP Act 1998 / HRIP Act 2002
• May be shared with regulators or law enforcement only as permitted by law
• Stored securely; access is strictly limited on a need-to-know basis
• Retained for at least 7 years (or longer if legally required or subject to legal hold)
• You may request access or correction (subject to legal constraints) via privacy@communityculture.org.au
Help and Wellbeing
• Riverlands Therapy Services (Penrith/Blue Mountains): (02) 4731 8111
• Fair Work Ombudsman: 13 13 94
• Safe Work Australia: info@swa.gov.au
If you’re concerned about immediate safety, call 000.
Accessibility and Languages
We can provide this page and our forms in accessible formats and other languages.
• Phone: 1300 646 444
• Email: governance@communityculture.org.au
• Interpreter: TIS National 131 450 → ask for 1300 646 444
Contact Points (quick reference)
• Whistleblower Protection Officer (WPO): via 1300 646 444 (ask for WPO)
• External Whistleblower Service: SDJA – Scott Carey 0477 927 508
• Aged Care Quality & Safety Commission: 1800 951 822
• NDIS Quality & Safeguards Commission: 1800 035 544
• NSW Office of the Children’s Guardian: (02) 8219 3600
• NSW DCJ – Child Protection Helpline: 132 111 (24/7)
• ASIC: asic.gov.au | ATO (tax): ato.gov.au | NSW Police: 131 444 / 000
FAQs
Q1. Can I be identified if I report anonymously?
We will not try to identify you. Some details in your report could allow others to guess. Share only what’s necessary, and use a non-identifying email or the external service if you’re worried.
Q2. Will I be told the outcome?
We’ll confirm receipt and provide updates where practicable and lawful. In some cases (e.g., regulator matters or privacy constraints), we may be limited in what we can disclose.
Q3. What if I was involved?
Telling us does not automatically shield you from outcomes for your own conduct, but co-operation, candour and remorse are relevant and retaliation remains prohibited.
Q4. How fast will you act?
We triage safety risks immediately, acknowledge within 7 days, aim for initial assessment in 14–21 days, and progress investigations as quickly as is fair and lawful.
Last updated: 26 October 2025