Whistleblower Policy
Corporate Policy

Version:

5.0

Issue Date:

12 January-2022

Whistleblower Policy

Table of Contents
PurposeScope

3

Responsibilities

3

What is Improper Conduct?

4

What should not be reported?

4

To whom, and how, should disclosures under this policy be made?
Disclosure Process - reporting Improper Conduct and Disclosable Matters

5

Reasonable Grounds

6

Confidentiality

6

Investigation of Improper Conduct
Whistleblower Protections

7

Fair Treatment
Commitment to protecting Whistleblowers

7

Whistleblower confidentiality

8

Detrimental Treatment

8

Keeping the Whistleblower informed
Protection of files and records

9

Other Protections available to Whistleblowers

Duty to Disclose Improper Conduct
General Reporting

10
10

Availability of Policy

10

Review of Policy

10

Breaches of Policy
Administration

11

Definitions

11

Fraud

11

Corruption

12

Misconduct

12

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Whistleblower Policy
An improper state of affairs or circumstances

12

Protected Disclosure

13

Eligible Whistleblower

13

References

14

Document Information
Appendix 1 - Australian Whistleblower Protection Laws

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Whistleblower Policy

PurposeProbe is committed to the highest standards of integrity and promoting a culture of honest and ethicalbehaviour, corporate compliance and good corporate governance.
In keeping with these standards of honesty, we actively encourage everyone in the business to challenge any
behaviour they believe is inconsistent with any of our values, our Workplace Conduct and Performance Policy, andthis Policy.
This Policy has been established to:
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encourage the reporting of Improper Conduct, unlawful and unethical behaviour;
help deter wrongdoing, in line with Probe’s risk management and governance framework;
ensure individuals who disclose wrongdoing can do so safely, securely and with confidence that they
will be protected and supported;
describe how Probe will protect the identity of persons making disclosures, and other persons
because a disclosure has been made, under this Whistleblower Policy and safeguard them fromdetriment and retaliation;
provide transparency around Probe’s framework for receiving, handling andinvestigating disclosures;
ensure Protected Disclosures (which are a special type of disclosure) are dealt withappropriately and on a timely basis; andensure Probe complies with its regulatory and legal obligations including the Treasury Laws Amendment(Whistleblower Protections) Act 2019 (Act).

This Policy is an important tool for helping Probe to identify wrongdoing and explains the operation ofwhistleblowing protections as they apply across Probe.
This Policy applies to Eligible Whistleblowers in relation to the Protected Disclosure of Improper Conduct andDisclosable Matters.

Scope
As Probe operates in multiple countries this Policy is subject to the law of those countries. This means that,in some cases, disclosures made under this Policy may be handled differently according to legislation or
regulation in that jurisdiction.
Australian Whistleblower Protection Laws outline in detail the rights and protections an Eligible Whistleblower
has in making a Protected Disclosure and extends to permitted disclosures that may be made to bodies or
persons outside the organisation. The specific requirements under Australian Whistleblower Laws are
addressed in Appendix 1 of this Policy.
This Policy is not intended to apply to customer complaints.

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Whistleblower Policy
The Eligible Whistleblower must refer to this policy or request protections under this policy when making
a Protected Disclosure.
Probe encourages Eligible Whistleblowers, or other persons, to raise issues or ask questions if:(a) they are unsure:●●●whether they are covered by this Policy;
whether their concerns qualify as a matter to be disclosed under this Policy; oras to who they should make a disclosure.

(b) They are the subject of a disclosure or a witness in an investigation of a disclosure and seek support
or assistance.
(c) They seek information about the type of protections and immunities available to Eligible
Whistleblowers, and other persons, under this policy.

Responsibilities
Managers are responsible for ensuring:●●●●

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they are familiar with the types of improprieties that might occur within their area of
responsibility and they are alert for any indication of Improper Conduct;
there is an open, transparent and safe working environment;
employees have ready access to this policy;
promotion and reporting of actual or suspected cases of inappropriate conduct and unethicalbehaviour; andIssue date 12 January2022

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Whistleblower Policy●

when an employee reports such matters on genuine grounds that Protected Disclosures are taken
seriously and acted on immediately and the necessary protections and support is provided.

All employees have the responsibility to report suspected Improper Conduct.
The Probe People Team is responsible for coordination of all Improper Conduct and Disclosable Matter investigations.

What is Improper Conduct?
A disclosure should be made if there are reasonable grounds to suspect that a Probe director, officer, employee,
contractor, supplier, tenderer or other person who has business dealings with Probe has engaged in Improper Conduct.
For the purpose of this Policy, Improper Conduct is defined as any of the following:●●●●

Corruption;
Fraud;
Misconduct; orAn improper state of affairs or circumstances.

All employees have the responsibility to report suspected Improper Conduct.
An Eligible Whistleblower should make a disclosure under this policy, and employees of Probe must make a disclosure
under this policy, if they reasonably suspect that conduct, or a state of affairs exists, in relation to Probe is a
Disclosable Matter.
A Disclosable Matter is defined as one of the following:
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Misconduct, or an improper state of affairs or circumstances;
Misconduct, or an improper state of affairs or circumstances, in relation to the tax affairs of Probe, and where
they consider the information may assist the recipient to perform functions and duties in relation to the tax
affairs of Probe;
Contravention of any law administered by Australian Securities and Investments Commission (ASIC) or
Australian Prudential Regulation Authority (APRA);
Conduct that represents a danger to the public or the financial system (even if this conduct does not involve a
breach of a particular law); or
Conduct that is an offence against any law of the Commonwealth, where the offence is punishable byimprisonment for a period of 12 months or more.

Further, a Disclosable Matter may include the following conduct:●●

May or may not involve a contravention of any law;
May include conduct that indicates a systemic issue in Probe;

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Whistleblower Policy●●●●

Relates to dishonest or unethical behaviour and practices;
May relate to business behaviour and practices that may cause consumer harm;
Is an exception to an excluded personal work-related grievance as defined in [insert];
Is prohibited under Probe’s policies available on their website (https://www.probegroup.com.au/)

A Disclosable Matter may relate to conduct or a state of affairs in relation to:●Related entities of Probe for disclosures under the Corporations Act 2001 (Cth) and Part IVD of the Taxation
Administration Act 1953 (Cth) (Tax Act), including: Probe Contact Solutions Australia Pty Ltd, Convai Pty
Limited, Probe Asia Pacific Pty Ltd, Beepo Support Services Pty Ltd, Probe Customer Management Pty Ltd andProbe Group Holdings Pty Ltd.

What should not be reported?
Subject to the exceptions set out below, a Disclosable Matter does not include a personal work-related grievance,
which concerns a grievance in relation to a whistleblower's employment, or former employment, with Probe that has
implications for the Whistleblower personally.
Examples of personal work related grievances include:
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an interpersonal conflict between the discloser and another employee;a decision that does not involve a breach of workplace laws;
a decision about the engagement, transfer or promotion of the discloser;a decision about the terms and conditions of engagement of the discloser; ora decision to suspend or terminate the engagement of the discloser, or otherwise to discipline thediscloser.

Personal work related grievances are managed under separate mechanisms and policies. A personal work related
grievance may still qualify for protection if:

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Whistleblower Policy
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it includes information about Misconduct, or information about Misconduct includes or isaccompanied by a personal work-related grievance (mixed report);
it relates to a breach of employment or other laws punishable by imprisonment for a period of 12months or more, engaged in conduct that represents a danger to the public, or the disclosure relates toinformation that suggests misconduct beyond the discloser’s personal circumstances;the discloser suffers from or threatened with detriment for making a disclosure;the discloser seeks legal advice or legal representation about the operation of thewhistleblower protections under the Australian Corporations Act 2001 (Cth).

If unsure whether a grievance relates to Improper Conduct under this Policy, or a personal work-related grievancethat is more appropriately managed through a relevant workplace behaviour policy of Probe, please seek
guidance from a Protected Disclosure Officer (see list below).

To whom, and how, should disclosures
under this Policy be made?
Probe requires that all disclosures be treated with the utmost seriousness and encourages Eligible
Whistleblowers to report Improper Conduct to one of the Protected Disclosure Officers set out below. It is our
objective to identify and address any wrongdoing as early as possible.
Name

Email

Elisha Parks (Whistleblower Investigations Officer)

elisha.parks@probegroup.com.au

Jarrod Kagan (Executive General Manager)

jarrod.kagan@probegroup.com.au

Jo Zaharopoulos (Senior Legal Counsel)

jo.zaharopoulos@probegroup.com.au

If a personal work related grievance may have a significant implication for Probe and wider ramifications for thewhistleblower personally, it may be appropriate to disclose the matter under this policy as a Disclosable Matter.
Where the grievance relates to detrimental conduct suffered by the Eligible Whistleblower because of making aprevious whistleblower disclosure, or seeking legal advice about whistleblower protections, the matter should bereported under this whistleblower policy as a Disclosable Matter (see below section regarding steps).
Without limiting the types of matters, examples of personal work-related grievances that could be reported as aDisclosable Matter under this whistleblower policy include:

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Whistleblower Policy

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Mixed reports, for instance where a concern regarding corporate misconduct or wrongdoing isaccompanied by a personal work-related grievance, or a personal work-related grievance includes
information about corporate misconduct or wrongdoing;
Where the matter suggests a behaviour or conduct extending beyond the individual's personal
circumstances, for instance an individual claim of bullying has indicated that there may be a more generalculture of bullying or harassment within Probe; orProbe or its officers or agents, has breached an employment (or other) law punishable by more than 12
months imprisonment, or has engaged in conduct that represents a danger to the public.

If unsure whether a grievance is a Disclosable Matter under this whistleblower policy, or a personal work related
grievance that is more appropriately managed through a relevant workplace behaviour policy of Probe, seek
guidance from the Whistleblower Investigations Officer (see above).
Disclosures that are not Disclosable Matters will not be afforded protection under the Corporations Act 2001 (Cth)and false reporting of any nature will not be tolerated.

Disclosure Process - reporting Improper
Conduct and Disclosable Matters
For a disclosure to be a Protected Disclosure, it must be made to people or entities eligible to receive them, as set
out below.
An Eligible Recipient in relation to Probe includes:●●●

An officer or senior manager of Probe;
An auditor or any member of the audit team; or
The individuals authorised by Probe to receive disclosures and set out in the table below.

Probe has identified the following individuals as eligible recipients of a disclosure regarding Improper Conduct.
Probe require that all disclosures be treated with the utmost seriousness and would encourage Eligible
Whistleblowers to report Improper Conduct to one of the listed Probe representatives set out below.
Name

Email

Elisha Parks (Whistleblower Investigations Officer)

elisha.parks@probegroup.com.au

Jarrod Kagan (Executive General Manager)

jarrod.kagan@probegroup.com.au

Jo Zaharopoulos (Senior Legal Counsel)

jo.zaharopoulos@probegroup.com.au

The position of Whistleblower Investigations Officer will be fulfilled by the Head of People who has primary
responsibility for conducting preliminary investigations into disclosure reports received by individuals under thispolicy and who is primarily responsible for receiving information (directly or anonymously via the STOPline) andprotecting an individual within the meaning of this policy. They may be assisted by the Probe Legal Services team.

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Whistleblower Policy
Alternatively a Protected Disclosure may be made via STOPline, an independent and confidential service available
to receive information relating to Improper Conduct, unlawful or unethical behaviour. Individuals have the option
to make anonymous reports to STOPline.
You can make contact with STOPline by:●●●●

Phone - 1300 30 45 50
Email - probegroup@stopline.com.au
Post - Probe Group, ℅ - Stopline, Locked Bag 8, Hawthorn, Victoria 3122
App - Search for Stopline in the iTunes App Store or Google Play to download the free app and submit a
disclosure

Within Australia under the Whistleblower Protection Laws an Eligible Whistleblower may disclose
Reportable Improper Conduct to an officer or senior manager of Probe, or to certain external bodies orindividuals.
Appendix 1 sets out the criteria for making such a disclosure of Reportable Improper Conduct and theprotections afforded that person under the Australian legislation.
Where possible, to assist Probe handle a disclosure made under this policy appropriately, an Eligible
Whistleblower should provide as much information as possible to enable Probe to investigate the disclosure
including any known details about the events underlying the disclosure such as:●●

entity, division or department which the Improper Conduct relates;
the nature of the alleged wrongdoing including, where relevant, details of the person believed tohave committed the wrongdoing;
when and where the wrongdoing occurred;anyone else who may verify the claim, or possible witnesses;
any supporting information; andif the Eligible Whistleblower is concerned about any possible victimisation or acts of reprisal forreporting the matter any assistance or support sought from Probe.

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You should provide as much information as possible to enable us to investigate the disclosure including any known
details about the events underlying the report such as date, time, location, witnesses, evidence of events, persons
involved etc.
Whistleblowers can also make Protected Disclosures to:
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ASIC
APRA
The Australian Federal Police
A legal practitioner.

A public interest disclosure can also be made to a journalist or parliamentarian if:●

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Whistleblower Policy●●●●

The Whistleblower has reasonable grounds to believe that action is not being, or has not been taken toaddress the disclosure;
The Whistleblower has reasonable grounds to believe that making a further disclosure would be in the
public interest;
The Whistleblower must be given written notification to the authority that they intend to make a public
interest disclosure;
The extent of the information disclosed is no greater than necessary to inform the recipient of the
misconduct or improper state of affairs to which the first disclosure related.

An emergency disclosure can be made when:●●

The Whistleblower had reasonable grounds to believe the information disclosed concerns a substantial
and imminent danger to the health and safety of one or more persons, or the natural environment;
The individual has previously made a disclosure to an eligible recipient and the Whistleblower has
provided a written notification that they intend to make an emergency disclosure.

Reasonable Grounds
A disclosure may have serious consequences, including potential damage to the career prospects and reputationof people who are the subject of allegations of wrongdoing. For this reason a Whistleblower must havereasonable grounds to suspect Improper Conduct in relation to Probe when making a disclosure under this Policy.

Confidentiality
Probe will take all reasonable steps to protect the identity of the Whistleblower. Probe will take all reasonable
steps to protect the identity of the Eligible Whistleblower.
Maintaining confidentiality is crucial in ensuring reprisals are not made against an Eligible
Whistleblower.
In addition, Probe will provide confidential means for an employee to make protected disclosures anonymously
and still be protected under the Corporations Act 2001 (Cth). This can be done via the STOPline, an independentand confidential service available to receive information relating to improper conduct, unlawful or unethicalbehaviour. It is important to note that in some circumstances it may be difficult for Probe to properly investigate
anonymous disclosures. We encourage Eligible Whistleblowers who wish to remain anonymous to maintainongoing two way communication with Probe so that Probe can ask follow up questions or provide feedback.

Investigation Process
The Whistleblower Investigation Officer will receive information regarding Protected Disclosures under this policy
from one of three sources:●●●

A Protected Disclosure directly from an Eligible Whistleblower
A Protected Disclosure from an Eligible Recipient
A Protected Disclosure via the STOPline (anonymously and confidentially if the Whistleblower chooses).

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Whistleblower Policy

After receiving a Disclosure from a Whistleblower under this policy, a recipient of the Disclosure will:(a)take all reasonable steps to ensure the Eligible Whistleblower’s identity is kept
confidential, subject to any permission given by the Whistleblower; and(b)

Determine whether the disclosure falls within the scope of this policy, or whether it is more
appropriately managed under another Probe policy.

Where the disclosure falls within the scope of this policy, Probe will commence the investigation of theReportable Improper Conduct within 5 business days of the initial disclosure.
A Protected Disclosure Officer may appoint a person(s) (including an external investigator) to assist in theinvestigation of the Reportable Improper Conduct.
The investigation will be conducted in a thorough, objective and fair manner. The investigation process will
depend on the nature and substance of the Reportable Improper Conduct. The object of an investigation into a
disclosure is to determine whether there is enough evidence to substantiate or refute the matters reported.
While the particular investigation process and enquiries adopted will be determined by the nature andsubstance of the Reportable Improper Conduct, a Protected Disclosure Officer or investigator will contact thediscloser to discuss the investigation process including who may be contacted and such other matters as are
relevant to the investigation.
An individual who is the subject of a Protected Disclosure (the respondent) may not be informed of the matter
until the Protected Disclosure Officer has completed a relevant and appropriate inquiry. In the interests ofnatural justice, this person(s) will have the right to make submissions and respond to an investigation before any
final determination is made regarding alleged Improper Conduct.
Where a disclosure is submitted anonymously, Probe will conduct the investigation and its enquiries based on
the information provided. As such, it may be difficult for Probe to keep an anonymous discloser updated andProbe’s ability to effectively investigate a disclosure may be impacted based on the level of information
provided.
Where appropriate, Probe will provide feedback to the discloser regarding the investigation’s progress and/or
outcome (subject to considerations such as the privacy of those against whom allegations are made orwhether the matter has been reported to relevant outside regulatory bodies or agencies that are runningparallel investigations etc.). The frequency and timeframe for such updates may vary depending on the natureof the disclosure.
Probe will endeavour to complete and satisfactorily close the investigation within 60 business days of its
commencement.
The Whistleblower Investigations Officer will maintain a record of all Protected Disclosures received and the action
taken. If the Disclosure/Investigations Officer judges the Protected Disclosure to be of significance, appropriate
action will be instigated immediately.

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Whistleblower Policy
If the action to be taken takes the form of an investigation, it must be demonstrably fair, independent andcomprehensive.
The Whistleblower Investigations Officer will immediately advise the Chief Financial Officer or the Chief Executive
Officer of significant Protected Disclosures and provide regular updates.
If the Whistleblower provides their contact details, a Disclosable Matter received by one of the methods listed
above, will be acknowledged as received within a reasonable time frame.
Subject to confidentiality obligations, the outcomes of any investigations of significant issues together with any
recommendations will be provided to the Chief Executive Officer, Chief Financial Officer and Senior Legal Counsel.
The duration and nature of the investigation process will vary depending on the nature of the Protected Disclosureand the amount of information provided and this will be communicated to the Whistleblower to ensure theprocess is transparent.
The nature and scope to be determined once receiving the disclosure will include the following:●●●●

The person within or external to Probe that will lead the investigation;
The nature of any technical, financial or specialist advice that may be required to support theinvestigation;
The timeframe for the investigation; andWhere the whistleblower has provided their identity to the Whistleblower Investigations Officer, seeking
consent for their identity to be revealed to the appointed Investigator.

Eligible Whistleblower Protection
Fair Treatment
Probe will investigate and record all Protected Disclosures confidentially, fairly and objectively.
A staff member who is the subject of a Protected Disclosure (the respondent) may not be informed of the matter
until the Whistleblower Investigations Officer has completed a relevant and appropriate inquiry. In the interests ofnatural justice, this person(s) will have the right to make submissions and respond to an investigation before any
final determination is made regarding alleged Improper Conduct.
The making of any malicious report of Improper Conduct that, on investigation, is shown to be without
foundation, will be treated as a serious matter in accordance with the Workplace Conduct and Performance Policy.
For the avoidance of doubt, where a person makes a report of Improper Conduct and:●●

believes on reasonable grounds that the information is true; oris not in a position to form a belief on reasonable grounds about the truth of the information but believes
on reasonable grounds that the information may be true and is of sufficient significance to justify its
disclosure so that the truth may be investigated that disclosure will not be deemed to be malicious for the
purposes of this Policy.

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Whistleblower Policy

A whistleblower, or other person, who has suffered loss, damage, injury caused by Detrimental Action or if Probe
fails to take reasonable precautions to prevent Detrimental Actions, the person may seek compensation or otherremedies through the courts of the applicable jurisdiction.
If the Whistleblower is not satisfied with the outcome of an investigation into their Disclosable Matter, they may
write to the Whistleblower Investigations Officer or the Senior Legal Counsel seeking a review of the outcome.

Commitment to protecting Eligible Whistleblowers
Probe is committed to the protection of genuine Whistleblowers against action taken in reprisal for the making ofProtected Disclosures. If deemed appropriate, a Welfare Manager from the People Team will be appointed tosupport the Whistleblower.
An Eligible Whistleblower who is a current or former Probe employee can access Probe’s confidential Employee
Assistance Program in the event they require support and assistance in connection with a disclosure.
While Probe may not be able to provide the same level of practical support to other Whistleblowers, we will lookat ways to provide support to the extent reasonably possible.

Whistleblower confidentiality
There is no requirement for a Whistleblower to disclose their identity in order to receive protection. During an
investigation, Probe will take all reasonable steps to protect the identity of the Whistleblower.
Probe acknowledges it is an offence to disclose the identity of a Whistleblower (without consent) unless to theAustralian Securities and Investments Commission (ASIC), the Australian Prudential Regulation Authority (APRA),
the Tax Commissioner or the Australian Federal Police (AFP) or a lawyer for the purposes of obtaining legal advice
or representation.
The failure to protect a Whistleblower’s identity may result in fines, penalties and imprisonment.
Upon receiving a disclosure of Improper Conduct under this policy, Probe will only share the disclosers
identity or information likely to reveal their identity if:i.

the discloser consents in writing;ii.

Probe is required by law to identify the discloser to relevant authorities;iii.
the matter is raised with lawyers for the purpose of obtaining legal advice orrepresentation in support of the investigation; oriv.
disclosure is necessary to prevent or lessen a threat to a person’s health, safety
or welfare.
During an investigation PROBE Group may disclose information that could lead to the discloser being
identified, but it will take reasonable steps to reduce this risk.

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Whistleblower Policy
Any disclosures regarding identity or information likely to reveal the identity of the discloser will be madeon a strictly confidential basis.
In addition, Probe provides a confidential means to make Protected Disclosures without revealing their identity
through the external STOPline service.

Protection of files and records
All files and records created from an investigation will be retained securely.
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)
will be a breach of this policy, unless the discloser has otherwise consented.

Detrimental action
Probe is committed to protecting Eligible Whistleblowers, and other persons, from detrimental conduct, or
threats of detrimental conduct, because a person believes or suspects that the Eligible Whistleblower (oranother person) has made, may have made, proposes to make, or could make a disclosure that qualifies forprotection under this policy.
A person cannot:(a)engage in conduct that causes detriment to an Eligible Whistleblower, or another person, if:(i)the person believes or suspects that the Eligible Whistleblower (or anotherperson) made, may have made, proposes to make, or could make, a disclosurethat qualifies for protection under Part A or B of this policy; and(ii)
the belief or suspicion is the reason, or part of the reason, for the conduct.
(b) threaten to cause detriment to an Eligible Whistleblower (or another person) in relation to adisclosure that qualifies for protection under applicable whistleblower protection laws (see Part A
and B).
All reasonable steps will be taken to ensure an Eligible Whistleblower will not be subject to any
detriment which includes (without limitation) any of the following:
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Dismissal
Injury of an employee in his or her employment
Alteration of an employee’s position or duties to his or her disadvantage
Discrimination between an employee and other employees
Harassment or intimidation of a person

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Whistleblower Policy
Harm or injury to a person, including psychological harm
● Damage to a person’s property● Damage to a person’s reputation● Damage to a person’s business or financial position● Any other damage to a person
as a result of making a Protected Disclosure.
The failure to comply with these obligations may result in fines, penalties and imprisonment.
If an Eligible Whistleblower is subjected to detrimental treatment as a result of making a disclosure under thispolicy they should inform a Protected Disclosure Officer immediately so appropriate action can be taken.
It is both a criminal and civil penalty offence to engage in detrimental conduct due to a belief or suspicion that a
qualifying or protected disclosure has been made, is believed to have been made, or could be made.

Keeping the Whistleblower informed
Where possible, and assuming the identity of the person making the disclosure is known, the Whistleblower
Investigations/Disclosure Officer or STOPline will ensure the Whistleblower is kept informed of the progress andoutcomes of the investigation, subject to privacy and confidentiality considerations where Probe or STOPline
determine a response is required or appropriate.

Other Protections Available to Eligible Whistleblowers Whistleblower
Where an eligible whistleblower makes a disclosure that qualifies for protection under the Corporations Act 2001 (Cth)or Tax Act, the Whistleblower is protected from any of the following in relation to the disclosure:●●●

Civil liability (for instance, legal action against the Whistleblower for breach of an employment contract, dutyof confidentiality or another contractual obligation);
Criminal liability (for instance, the attempted prosecution of the Whistleblower for unlawfully releasing
information, or other use of the disclosure against the whistleblower in a prosecution, other than making a
false disclosure); and/or
Administrative liability (for instance, disciplinary action for making the disclosure).

Duty to Disclose Improper Conduct
It is expected that Probe employees who become aware of actual cases of Reportable Improper Conduct, or who
suspect (on reasonable grounds) potential cases of Reportable Improper Conduct, will make a disclosure under thispolicy.

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Whistleblower Policy

General Reporting
Each quarter a report is made to the Chief Executive Officer summarising the Whistleblowing activities for the period
and to enable Probe to identify any systemic issues across its businesses. This report may be used to make general
proposals to improve the compliance culture of Probe.
The Chief Executive Officer presents this report to the Board. Board Reports will be made on a ‘no names’ basis,
maintaining the confidentiality of matters raised under this policy and, crucially, the discloser of Reportable
Improper Conduct.

Availability of Policy
This policy will be available on Probe’s intranet which includes a link to STOPline, Probe’s website, incorporated into
the online employee induction training for new employees, and is available in hard copy upon request.Eligible
Recipients receive periodic training to ensure they understand their obligations under this policy and all Probeemployees complete annual online training in connection with their whistleblowing rights and obligations.

Review of Policy
Probe is committed to monitoring and reviewing the effectiveness of this policy and its related processes andprocedures. This policy will be reviewed at least every two years by the Senior Legal Counsel of Probe to ensure it
complies with relevant laws and remains relevant and effective.
This policy does not impose any contractually binding obligations on Probe or create contractual rights for employees.
Probe reserves the right to vary this policy from time to time at its discretion.

Breaches of Policy
Disclosers are assured that a release of information in breach of this policy will be regarded as a serious matterand will be dealt with in accordance with Probe Group’s disciplinary procedures. In particular, any breach ofconfidentiality of the information provided by an Eligible Whistleblower, or an Eligible Whistleblower’s identity,
and any retaliation against a whistleblower, will be taken seriously and if appropriate will be separately
investigated.
An individual who is found to have disclosed the information or to have retaliated (or threatened to retaliate)against an Eligible Whistleblower may be subject to further action (including disciplinary action in the case of
employees). An individual may also be exposed to criminal or civil liability for a breach of relevant legislation.
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Whistleblower Policy

The making of any malicious, vexatious or untrue report of Improper Conduct that, on investigation, is shown to bewithout foundation, will be treated as a serious matter in accordance with the workplace conduct policy. For the
avoidance of doubt, where a person makes a report of Improper Conduct and:●●

believes on reasonable grounds that the information is true; oris not in a position to form a belief on reasonable grounds about the truth of the information but
believes on reasonable grounds that the information may be true and is of sufficient significance tojustify its disclosure so that the truth may be investigated that disclosure will not be deemed to bemalicious for the purposes of this policy.

Probe reserves the right not to investigate reports that it considers to be malicious, vexatious or knowingly untrue.

Administration
This Policy is not a term of any contract, including any contract of employment, and does not impose any
contractual duties, implied or otherwise, on any Probe entity and may be amended at any time.

Definitions
Fraud
For the purpose of this policy, fraud is defined as:“dishonest activity causing actual or potential financial loss to any person or entity including, but not limited to, theftof moneys or other property by employees or persons external to the entity and whether or not deception is used at
the time, immediately before or immediately following the activity. This also includes the deliberate falsification,
concealment, destruction or use of falsified documentation used or intended for use for a normal business purpose or
the improper use of information or position.”

Actions constituting Fraud
The terms defalcation, misappropriation, and other fiscal wrongdoings refer to, but are not limited to:● any dishonest or fraudulent act● forgery or alteration of any document or account belonging to Probe● misappropriation of funds, securities, supplies, or other assets● impropriety in the handling or reporting of money or financial document● profiteering as a result of insider knowledge or company activities● disclosing confidential and proprietary information to outside parties● accepting or seeking anything of material value from contractors, vendors or persons providing
services/materials to Probe.
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Whistleblower Policy●●●

customers or parties not employed by Probe who commit Fraud or Corruption against Probe or its customers;
destruction, removal or inappropriate use of records, furniture, fixtures, and equipment
any similar or related inappropriate conduct.

Corruption
For the purpose of this policy, corruption is defined as:● “dishonest activity in which a director, executive, manager, employee or contractor of an entity acts contrary
to the interests of the entity and abuses his/her position of trust in order to achieve some personal gain oradvantage for him or herself or for another person or entity.”This includes the offering or accepting of bribes.

Misconduct
For the purpose of this policy, Misconduct may include but is not limited to:● fraudulent/dishonest behaviour● Unethical conduct● Mismanagement of Probe resources● Any conduct or activity that poses a serious risk to the health and safety of any person at the workplace● A breach of any legislation or regulations relating to Probe’s operations or activities● Illegal activities (including theft, dealing in or use of illicit drugs, violence or threatened violence and criminal
damage against property)● Any activity that causes a risk or harm to the environment● Behaviour that is oppressive, discriminatory or grossly negligent● A failure to abide by Probe policies and procedures● Any conduct that brings Probe into disrepute or which damages or has the potential to damage the reputationof Probe.

An improper state of affairs or circumstances
For the purposes of this policy, an improper state of affairs or circumstances includes:● A contravention of the Corporations Act 2001, ASIC Act 2001, the Banking Act 1959, Financial Sector(Collection of Data) Act 2001, Insurance Act 1973, Life Insurance Act 1995, the National Consumer Credit
Protection Act 2009, the Superannuation Industry (Supervision) Act 1993 or an instrument made under one ofthese laws;● Conduct that constitutes an offence against any other Commonwealth law that is punishable by imprisonment
for a period of 12 months or more;● Conduct that represents a danger to the public or the financial system; or● Conduct that is prescribed by the regulations for the purposes of the Treasury Laws Amendment(Whistleblower Protections) Act 2019 (Act).

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Whistleblower Policy

Protected Disclosure
For the purpose of this policy, protected disclosure is defined as:● “Any communication based on reasonable grounds that discloses or demonstrates an intention to disclose
information that may evidence Improper Conduct or such other reportable conduct that is described as a
Protected Disclosure in an Appendix to this policy under a law that applies to the geographic location in which
the discloser is based.”This Policy does not apply to a disclosure of information by an individual to the extent that the information disclosed
concerns a personal work-related grievance of the discloser unless the disclosure concerns alleged victimisation under
this Policy. Personal work related grievances are managed under separate mechanisms and policies.

Eligible Whistleblower
For the purpose of this policy, an Eligible Whistleblower is defined as:
Anyone who is or has been:● An employee, director or officer of Probe;● A contractor (including employees of contractors) of Probe;● A supplier (including employees of a supplier) to Probe;● An associate of Probe;● A relative or dependent of any of the above categories; or● An individual prescribed by law as an Eligible Whistleblower;● who whether anonymously or not, makes or attempts to make a protected disclosure regarding Improper
Conduct.
The Eligible Whistleblower must refer to this policy or request protections under this policy when making a disclosure.

References
Treasury Laws Amendment (Whistleblower Protections) Act 2019 (Act)Workplace Conduct and Performance Policy

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Whistleblower Policy

Document Information© Copyright 2020. The information in this document is for the sole use of Probe staff and employees. It contains
Probe’s confidential information. No part of it may be copied, reproduced, translated, or reduced to any electronic
medium or machine-readable form without prior written consent. This document should not be circulated outside
Probe without the written consent of the Release Authority. Where no release authority is listed, a Senior Manager’s
written consent must be obtained before the document is circulated outside Probe.

Change history
Version

Date

ChangeAuthorReviewer(s)*1.025-Jun-18

First Probe Version

D ReidJ Zaharopoulos/
E Parks

6-May-19

Amendment to include STOPline details,
mandatory content to comply with the Treasury
Laws Amendment (Whistleblower Protections)
Act 2019 (Act) and changed title from “Doing theRight thing Policy.”

2.0

J Zaharopoulos

D Reid3.0

25-Aug-20

Annual review - update to contact details

J Zaharopoulos

4.0

2-Mar-21

Rebrand to Probe CX

5.0

12 January
2022

Annual review

Eve Dani
Madeleine Hearn

J Zaharopoulos

Release authorisation
Version

5.0

Release date

12 January 2022

Release authority

Senior Legal Counsel

Release Name

Jo Zaharopoulos

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Whistleblower Policy

Appendix 1 - Australian
Whistleblowers Protection Laws
PurposeIn Australia, the Corporations Act 2001 (Cth) (Corporations Act) and the Taxation Administration Act 1953 (Cth)(Taxation Administration Act) both provide protections for persons who make an eligible disclosure.
The purpose of this Appendix is to ensure Probe’s Australian entities (Probe Contact Solutions Australia Pty Ltd,
Convai Pty Limited, Probe Asia Pacific Pty Ltd, Beepo Support Services Pty Ltd, Probe Customer Management Pty Ltd
and Probe Group Holdings Pty Ltd) comply with the Australian Whistleblower Protection Laws that are designed to:●●●

Avoid fraud and corporate wrongdoing;
Promote the reporting of fraud and corporate wrongdoing whilst protecting Eligible
Whistleblowers from discrimination; andMaintain Whistleblower confidentiality.

This Appendix applies when:
1)

The whistleblower is an Eligible Whistleblower; and2)

Their disclosure is made to an Eligible Recipient; and3)

The disclosure is a Protected Disclosure.

The circumstances to determine whether there is a Protected Disclosure made by an Eligible Whistleblower
to an Eligible Recipient are set out in Part A (Special Protections under the Corporations Act) and Part B(Special Protections under the Taxation Administration Act) of this Appendix.
Disclosures that are not Protected Disclosures do not qualify for protection under the Whistleblower Protection
Laws. Non-qualifying disclosures may however be protected under other legislation, such as in Australia the Fair
Work Act 2009 (Cth). Further non-qualifying disclosures may still fall within Probe’s broader Policy Whistleblowing
for investigating alleged wrongdoing.
It is recommended that potential whistleblowers seek the advice of an independent legal adviser before making a
disclosure to a regulator or other permitted persons, including when making a Public Interest Disclosure or an
Emergency Disclosure as outlined in this Appendix.

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Whistleblower Policy
It is important that a potential whistleblower understands the criteria for protection under the relevant
legislation.

Scope
This Appendix applies to Probe employees, contractors, directors and other persons identified in this Appendix as it
relates to Probe’s Australian entities (Probe Contact Solutions Australia Pty Ltd, Convai Pty Limited, Probe Asia Pacific
Pty Ltd, Beepo Support Services Pty Ltd, Probe Customer Management Pty Ltd and Probe Group Holdings Pty Ltd).
References to Probe in this Appendix are directly referring to Probe’s Australian entities.

PART ASpecial Protections under the Corporations Act [1]
The Corporations Act gives special protection to disclosures about any misconduct or improper state of affairs
relating to Probe if the following conditions are satisfied:(a)the whistleblower is or has been:i.

an officer or employee of Probe;ii.

an individual who supplies goods or services to Probe or an employee of a person who
supplies goods or services to Probe;iii.

an individual who is an associate of Probe; oriv.

a relative, dependent or dependent of the spouse of any individual referred to at (i) to(iii) above(all being ‘Eligible Whistleblowers’);(b)Version 5.0

the disclosure is made to:i.

a Probe Protected Disclosure Officer;

ii.

an officer or senior manager of Probe [2];iii.

Probe’s external auditor (or a member of that audit team)[3];iv.

an actuary of a Probe [4];v.

the Australian Securities & Investments Commission (ASIC);

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Whistleblower Policyvi.

the Australian Prudential Regulation Authority (APRA); orvii.
a legal practitioner for the purpose of obtaining legal advice or legal
representation in relation to the operation of the whistleblower provisions in the
Corporations Act (all being ‘Eligible Recipients’); and(c)the Eligible Whistleblower has reasonable grounds to suspect that the information being disclosed
concerns misconduct, or an improper state of affairs or circumstances in relation to Probe. This may include
a breach of legislation including the Corporations Act, an offence against the Commonwealth punishable byimprisonment for 12 months or more, or conduct that represents a danger to the public or financial system(being a ‘Protected Disclosure’).
Examples of conduct which may amount to a breach of the Corporations Act include: insider trading, insolvent
trading, breach of the continuous disclosure rules, failure to keep accurate financial records, falsification of
accounts, failure of a director or other officer of Probe to act with the care and diligence that a reasonable person
would exercise, or to act in good faith in the best interests of the corporation or failure of a director to give notice ofany material personal interest in a matter relating to the affairs of Probe.
(d)

The protections given by the Corporations Act when these conditions are met are:i.
the Eligible Whistleblower is immune from any civil, criminal oradministrative legal action (including disciplinary action) for making the Protected
Disclosure;ii.no contractual or other remedies may be enforced, and no contractual or other right may
be exercised, against the Eligible Whistleblower for making the Protected Disclosure;iii. in some circumstances, the reported information is not admissible against the Eligible
Whistleblower in criminal proceedings or in proceedings for the imposition of a penalty[5] ;iv. anyone who causes or threatens to cause detriment to a Eligible Whistleblower oranother person in the belief or suspicion that a Protected Disclosure has been made, or may havebeen made, proposes to or could be made, may be guilty of an offence and may be liable fordamages;v. an Eligible Whistleblower's identity cannot be disclosed to a Court or tribunal except
where considered necessary; andvi. the person receiving the Protected Disclosure commits an offence if they disclose thesubstance of the disclosure or the Eligible Whistleblower’s identity, without the Eligible
Whistleblower’s consent, to anyone except ASIC, APRA, the Australian Federal Police (AFP) or alawyer for the purpose of obtaining legal advice or representation in relation to the disclosure.

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Whistleblower Policy

Confidentiality
If a Protected Disclosure is made, the identity of the Eligible Whistleblower must be kept confidential unless one of
the following exceptions applies:(a)the Eligible Whistleblower consents to the disclosure of their identity;(b)disclosure of details that might reveal the Eligible Whistleblower’s identity and isreasonably necessary for the effective investigation of the matter;(c)the concern is reported to ASIC, APRA, or the AFP; or(d)the concern is raised with a lawyer for the purpose of obtaining legal advice orrepresentation.

Public Interest and Emergency Disclosure
An Eligible Whistleblower may also be eligible to make a Protected Disclosure that qualifies for protection under the
Whistleblower Protection Laws to a journalist or to a “Member of Parliament” (being a Member of an AustralianCommonwealth or State Parliament or an Australian Territory Legislature) – provided the criteria set out below
under the heading “Public Interest Disclosure” are met.
An Eligible Whistleblower will only qualify for protection if they have previously made a Protected Disclosure to
ASIC, APRA, or another Commonwealth body prescribed.
Note: Public Interest and Emergency Disclosures do not apply to the Australian Tax Office (ATO) in respect of tax
affairs.

Public Interest Disclosure
A Public Interest Disclosure is a Protected Disclosure made to a journalist or Member of Parliament where:(a)at least 90 days have passed since the previous making of a Protected Disclosure to ASIC, APRA or
another prescribed Commonwealth body;(b)
the Eligible Whistleblower does not have reasonable grounds to believe that action has been,or is being taken in relation to their Protected Disclosure;(c)
the Eligible Whistleblower has reasonable grounds to believe that making a further
disclosure is in the public interest;(d)the Eligible Whistleblower has given prior written notice to ASIC or APRA, or the Commonwealthbody to which they made their previous Protected Disclosure, outlining that they intend to make a Public
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Whistleblower Policy
Interest Disclosure and providing sufficient information so as to identify their previous Protected
Disclosure; and(e)the extent of the information disclosed in the Public Interest Disclosure is no greater than toinform the journalist or Member of Parliament of the misconduct or improper state of affairs or
circumstances, or other conduct falling within the scope of the Whistleblower Protection Laws.

Emergency Disclosure
An Emergency Disclosure is a disclosure made to a journalist or Member of Parliament where:(a)a Protected Disclosure has previously been made to ASIC, APRA, or another prescribed
Commonwealth body;(b)
the Eligible Whistleblower has reasonable grounds to believe that the information concerns asubstantial and imminent danger to the health or safety of one or more persons or to the naturalenvironment;(c)the Eligible Whistleblower has given prior written notice to the Commonwealth body to which
they made their previous Protected Disclosure, outlining that they intend to make an Emergency
Disclosure and providing sufficient information so as to identify the previous Protected Disclosure; and(d)only includes information to the extent necessary to inform the journalist or Member ofParliament of the substantial and imminent danger is disclosed.

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PART B
Special Protections under the Taxation Administration Act
The Taxation Administration Act gives special protection to disclosures about a breach of any Australian
tax law by Probe or misconduct in relation to Probe’s tax affairs if the following conditions are satisfied:(a)the whistleblower is or has been:i.

an officer or employee of Probe;ii. an individual who supplies goods or services to Probe or an employee of a person who
supplies goods or services to Probe;iii.

an individual who is an associate of a Probe;

iv. a spouse, child, dependent or dependent of the spouse of any individual referred
to at (i) to (iii) above(all being ‘Eligible Whistleblowers’);(b)

the disclosure is made to:i.

a Probe Protected Disclosure Officer;

ii.

a director, secretary or senior manager of Probe;iii.

any Probe external auditor (or a member of that audit team)[6];iv.

registered tax agent or BAS agent who provides tax or BAS services to Probe [7];v. any other employee or officer of Probe who has functions or duties relating to tax
affairs of Probe (e.g. an internal accountant);vi.

the Commissioner of Taxation (Tax Commissioner); or

vii. a legal practitioner for the purpose of obtaining legal advice or legal representation in
relation to the operation of the whistleblower provisions in the Taxation Administration Act(all being ‘Eligible Recipients’); and(c)Version 5.0

if the disclosure is made to a Probe recipient, the Eligible Whistleblower:

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Whistleblower Policyi. has reasonable grounds to suspect that the information indicates misconduct, or an
improper state of affairs or circumstances, in relation to the tax affairs of a Probe or an associate ofProbe; andii. considers that the information may assist the Probe recipient to perform functions or
duties in relation to the tax affairs of a Probe or an associate of Probe; and(d) if the disclosure is made to the Tax Commissioner, the Eligible Whistleblower considers that the information
may assist the Probe recipient to perform functions or duties in relation to the tax affairs of a Probe or an
associate of Probe (being a ‘Protected Disclosure’).
The protections given by the Taxation Administration Act when these conditions are met are:(a)the Eligible Whistleblower is immune from any civil, criminal or administrative legal action(including disciplinary action) for making the disclosure;(b)
no contractual or other remedies may be enforced, and no contractual or other right may be
exercised, against the Eligible Whistleblower for making the disclosure;(c)where the Protected Disclosure was made to the Tax Commissioner, the reported information is
not admissible against the Eligible Whistleblower in criminal proceedings or in proceedings for theimposition of a penalty, except where the proceedings are concerned with whether the information isfalse;(d)unless the Eligible Whistleblower has acted unreasonably, an Eligible Whistleblower cannot beordered to pay costs in any legal proceedings in relation to a disclosure;(e)anyone who causes or threatens to cause detriment to an Eligible Whistleblower or anotherperson in the belief or suspicion that a disclosure has been made, or may have been made, proposes toor could be made, may be guilty of an offence and liable to pay damages;(f)an Eligible Whistleblower's identity cannot be disclosed to a Court or tribunal except whereconsidered necessary; and(g)the person receiving the disclosure commits an offence if they disclose the substance of thedisclosure or the Eligible Whistleblower’s identity, without the their consent, to anyone except the Tax
Commissioner, the AFP or a lawyer for the purpose of obtaining legal advice or representation in relation
to the disclosure.

Confidentiality
If a Protected Disclosure is made, the identity of the Eligible Whistleblower will be kept confidential unless one of
the following exceptions applies:(a)Version 5.0

the Eligible Whistleblower consents to the disclosure of their identity;
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Whistleblower Policy(b)disclosure of details that might reveal the Eligible Whistleblower’s identity is reasonably
necessary for the effective investigation of the allegations;(c)the concern is reported to the Tax Commissioner or the AFP; or(d)the concern is raised with a lawyer for the purpose of obtaining legal advice orrepresentation.

[1] See Part 9.4AAA of the Corporations Act 2001 (Cth).
[2] Officer and senior manager are defined in the Corporations Act as “a director, or senior manager who makes, orparticipates in make decisions that affect the whole, or substantial part, of the business of Probe, or who has thecapacity to affect significantly Probe’s financial holding.”[3] Probe’s external auditor at 12 January 2022 is PricewaterhouseCoopers, Lisa Harker, Lead Auditor contact - Ethics
and Conduct Helpline 1800 I TRUST (1800 487 878).
[4] Probe’s actuary at 12 January 2022 is PricewaterhouseCoopers, Lisa Harker, Lead Auditor contact - Ethics andConduct Helpline 1800 I TRUST (1800 487 878).
[5] Such as where the disclosure has been made to ASIC or APRA, or where the disclosure qualifies as a public
interest or emergency disclosure.
[6] Probe’s external auditor at 12 January 2022 is PricewaterhouseCoopers, Lisa Harker, Lead Auditor contact - Ethics
and Conduct Helpline 1800 I TRUST (1800 487 878).
[7] Probe’s tax agent at 12 January 2022 is PricewaterhouseCoopers, Lisa Harker, Lead Auditor contact - Ethics andConduct Helpline 1800 I TRUST (1800 487 878).

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