Whistleblowing Policy

Date 29 May 2026

The Australian Public Policy Institute (APPI) is committed to fostering a culture of integrity, transparency, accountability and respect across all areas of its operations. APPI believes all staff, partners and stakeholders should feel safe, supported and empowered to raise concerns about misconduct, unethical behaviour or practices that may not align with APPI’s values or legal obligations.

Recognising that some matters may require independent escalation or confidential reporting, APPI has established this Whistleblowing Policy to provide a safe, secure and transparent framework for reporting concerns relating to misconduct or improper conduct. APPI is committed to ensuring disclosures are handled fairly, confidentially and in accordance with applicable legal protections.

1. PURPOSE

1.1 The Australian Public Policy Institute is committed to high standards of corporate governance and to maintaining a culture of honest and ethical behaviour.

1.2 The objectives of the APPI Whistleblowing Policy is to:

• Help deter wrongdoing relating to APPI’s operations, by encouraging disclosure of wrongdoing
• Ensure that anyone who makes a disclosure can do so safely, securely and with confidence that they will be protected and supported.
• Ensure that disclosures are dealt with in a timely and appropriate manner
• Meet APPI’s legal and regulatory obligations.

 

2. SCOPE

2.1 The following persons are capable of being ‘eligible whistleblowers’:

• Directors of APPI;
• Partners of and/or suppliers of services to APPI (university partners, project partners, professional accounting personnel etc);
• Employees of APPI (including permanent, part-time, fixed-term or temporary, interns, secondees and managers);
• An individual who is an associate of APPI.

An ‘eligible whistleblower’ also includes an individual who:

• Previously held any of the positions or functions above;
• Is a relative, dependent or spouse (or the dependent of a spouse) of the individuals set out above.

 

3. REPORTABLE CONDUCT

3.1 Reportable conduct includes any past, present or likely future activity which:

• Is dishonest, corrupt or unethical
• Involves theft, fraud, money laundering or misappropriation of funds
• Is a systemic, wilful or serious breach of the law as it relates to APPI, or its internal policies or processes
• Involves offering or accepting a bribe from any person
• Is illegal (e.g. illicit drug sale or use, violence or threatened violence and criminal property damage)
• Presents a significant or serious threat to the health and safety of workers
• Involves a serious mismanagement of APPI’s resources
• Involves victimisation of someone for reporting a reportable conduct
• Involves any instruction to cover up or attempt to cover up serious wrongdoing
• Interferes with any impending internal or external audit processes
• Presents a serious risk to the reputation or financial wellbeing of APPI

 

3.2 The APPI Whistleblowing Policy is not intended to apply to disclosures relating to conduct concerning a person’s individual employment (other than as set out above). The following are examples not considered reportable conduct:

• Personal, work-related grievances such as those relating to harassment, discrimination or disciplinary matters;
• Alleged workplace discrimination or bullying;
• Personal disputes between staff; or
• Decisions regarding the engagement, transfer or promotion of staff.

 

3.3 In circumstances where APPI is engaged under Federal or State Government contracts, reportable conduct may extend to include “disclosable conduct” such as conduct that:

• Perverts, or attempts to pervert, the course of justice;
• Constitutes maladministration (i.e. conduct that breaks the law, is unreasonable, unjust, or improperly discriminatory, or based wholly or partly on improper motives);
• Is an abuse of public trust;
• Results in the wastage of any public money or money held by the Commonwealth / a corporate Commonwealth entity;
• Results in the wastage of any property (other than money) that is owned by or held by the Commonwealth / a corporate Commonwealth entity; or
• Results in a danger, or a risk of danger, to the environment.

 

4. PROCESS

4.1 Making a Whistleblowing Disclosure

4.1.1 APPI encourages disclosures to be made internally to the persons set out below (referred to as Authorised Recipients). Reports should, in the first instance, be made to the Authorised Recipient that the eligible whistleblower believes is best placed to handle the report considering its importance, any person(s) who are the subject(s) of the report, and any other relevant factors.

4.1.2 Authorised Recipients at APPI are as follows:

• • Chair of the APPI Finance, Audit & Risk Committee
  • Chair of the APPI Board
  • APPI CEO

4.1.3 If the disclosure relates to the CEO or a Director of the Institute, it should be raised directly with the Chair of the APPI Board or Chair of the Finance, Audit & Risk Committee.

4.1.4 If an eligible whistleblower does not feel comfortable raising their disclosure with an Authorised Recipient, they could also raise a disclosure with any of the following:

• • A Director of APPI
  • APPI’s designated contact at the NSW Department of Education
  • APPI’s external audit partner Hardwickes, or
  • External regulatory bodies, such as ASIC, APRA , the ATO (for tax matters) or a prescribed Commonwealth authority

4.1.4 The APPI Whistleblowing Policy does not affect, or derogate from, any mandatory reporting requirement that APPI may have under any other Commonwealth or State/Territory law.

4.2 Protections for the Whistleblower

4.2.1 Important protections relating to confidentiality and detriment apply to eligible whistleblowers who report disclosable matters in accordance with the APPI Whistleblower Policy. The protections apply to internal disclosures as well as to disclosures to legal practitioners, regulatory and other external bodies, and public interest and emergency disclosures that are made in accordance with the APPI Whistleblowing Policy.

4.2.2 Strict confidentiality obligations apply in respect of any disclosures that qualify for protection under the APPI Whistleblowing Policy.
Unless the eligible whistleblower consents, it is against the law for a person to disclose an eligible whistleblower’s identity or any information that may lead to their identification (subject to the exceptions set out below in 4.2.4).

4.2.3 APPI takes protection of an eligible whistleblower’s identity very seriously. Steps it will take to help achieve this include:

• • maintaining mechanisms to reduce the risk that the eligible whistleblower will be identified from the information contained in a disclosure (such as redactions or referring to the person in gender neutral terms, etc);
  • maintaining mechanisms for secure record-keeping and information-sharing processes and limiting access to records and information;
  • reminding each person (as appropriate) who is involved in handling and investigating a disclosure about the confidentiality requirements, including that an unauthorised disclosure of an eligible whistleblower’s identity may be a criminal offence.

4.2.4 In practice, it is important to recognise that an eligible whistleblower’s identity may still be determined if the eligible whistleblower has previously mentioned to other people that they are considering making a disclosure, the eligible whistleblower is one of a very small number of people with access to the information or the disclosure related to information that an eligible whistleblower has previously been told privately and in confidence.

4.2.5 If there is a breach of confidentiality, an eligible whistleblower can lodge a complaint with an Authorised Recipient or a regulator such as ASIC for investigation.

4.2.6 APPI cannot pursue action against the eligible whistleblower.
An eligible whistleblower is protected from any civil liability, criminal liability and/or administrative liability (including disciplinary action) for making a qualifying disclosure in accordance with the Whistleblower Protection Scheme, and no contractual or other remedy may be enforced or exercised against the eligible whistleblower based on a qualifying disclosure. However, the protections do not grant immunity for any misconduct an eligible whistleblower has engaged in that is revealed in their disclosure.

4.3 The Investigation Process

4.3.1 Where practicable, APPI will acknowledge receipt of an eligible whistleblower disclosure within 10 business days, assuming the ‘eligible whistleblower’ can be contacted (including through anonymous channels). APPI will assess disclosures to determine whether:

(a) they fall within the APPI Whistleblowing Policy;

(b) the disclosure constitutes reportable conduct, and

(c) an investigation is required – and if so, how that investigation should be carried out.

4.3.2 Generally, if an investigation is required, APPI will determine:

• • the nature and scope of the investigation;

• • who should lead the investigation – including whether an external investigation is appropriate;
  • the nature of any technical, financial or legal advice that may be required to support the investigation; and
  • the anticipated timeframe for the investigation. Each investigation will be different which will impact the applicable timeframe. However, APPI’s intent is to complete an investigation as soon as practicable.

 

4.3.3 APPI, via its investigator and/or the Authorised Recipient, will provide the whistleblower with regular updates regarding the investigation, unless doing so compromises the integrity of the investigation or confidentiality of others involved. Where practicable, APPI will provide updates as follows:

• • Confirmation that an investigation has formally commenced, including confirmation of the designated point of contact,
  • Notification that the investigation is ongoing approximately every 30 days,
  • Notification that the investigation is nearing conclusion, and
  • Notification that the investigation has been finalised.

 

4.4 Obligations to Other Persons involved in the Whistleblowing Process

4.4.1 Procedural fairness to subjects of whistleblower disclosures

The subject of the disclosure:

• • Will be notified that an investigation is underway at a point where doing so will not compromise the integrity of the investigation. This may include deferral of notification where there is a risk of interference with evidence or where a regulator is involved.
  • Will be provided with sufficient detail of the allegations (without identifying the whistleblower) to allow them a meaningful opportunity to respond before any adverse findings are made.

 

4.4.2 Other parties to the investigation process

Individuals outside of the whistleblower and subject may be interviewed or otherwise involved as part of the investigation process. These individuals:

• • Will be informed in general terms of the nature and purpose of the investigation at the time of their involvement, without disclosing the identity of the whistleblower or unnecessary details of the disclosure.
  • Are placed under express confidentiality obligations in respect of their
    participation. This includes not discussing the investigation with colleagues;
  • Will be informed that participation does not imply any allegation or adverse inference, and that they are protected from victimisation under the APPI Whistleblowing Policy.
  • May be notified once the investigation is finalised, even if the specific outcome is not disclosed to them.

 

4.5 Reporting of Outcomes

4.5.1 To APPI’s Governing Bodies

• • A report of the findings of whistleblower investigations will be provided in all instances to the APPI Finance, Audit & Risk Committee (as a formal sub-committee of the APPI Board)
  • A report of findings will be provided to the APPI Board where, as determined by the Chair of the Finance, Audit and Risk Committee, there are material or significant matters. This may include where:
    • The findings involve substantiated misconduct, surface systemic issues or regulatory implications, or
    • Other matters that engage the Board’s governance responsibilities

 

4.5.2 To the Whistleblower

As a default, the whistleblower will be informed of the general outcome of the investigation, subject to prohibitions concerning the disclosure of confidential information.

Limitations on disclosure of outcomes: there may be circumstances where outcome information may be withheld, such as in the event that sharing such information would:

• • Identify or risk identifying another individual involved in the investigation
  • Prejudice any ongoing internal or external investigation or regulatory process, or
  • Otherwise be inconsistent with APPI’s confidentiality obligations or statutory whistleblower protections.

 

Mutual responsibility with regard to confidentiality: confidentiality obligations apply not only to APPI in handling the whistleblower’s identity and disclosure, but also to the whistleblower in relation to any information about the investigation or outcome that is communicated to them.

4.5.3 To the subject

Following consideration of the confidentiality protections owed to the whistleblower under the Policy and the Corporations Act, the subject will be informed by the designated point of contact of the outcome of the investigation. This can include:

• • Whether the allegations were substantiated, partially substantiated or not substantiated, and
  • Any action to be taken in respect of these outcomes.

 

4.5.4 Implications of Outcomes on the Subject

Investigative findings may inform subsequent employment, disciplinary or governance processes, which are conducted separately and subject to their own procedural requirements.

The whistleblower investigation in itself does not constitute a disciplinary determination.

4.6 Legal, Emergency, Public Interest & Other Disclosures

4.6.1 Disclosure to a legal practitioner

A report of a disclosable matter will also be protected if it is to a qualified legal practitioner for the purpose of taking legal advice or legal representation in relation to the operation of the whistleblower provisions under law.

4.6.2 Emergency Disclosures

‘Emergency disclosures’ also qualify for protection. These can be made to journalists and members of Parliament but only if the eligible whistleblower complies with the following strict requirements:

• • the eligible whistleblower must have first made a qualifying disclosure to ASIC, APRA , the ATO (for tax matters) or a prescribed Commonwealth authority;
  • the eligible whistleblower has reasonable grounds to believe that the information concerns a substantial and imminent danger to the health or safety of one or more persons or to the natural environment;
  • the eligible whistleblower gave notice to the body to which the qualifying disclosure was made that states:
    • that they intend to make an emergency disclosure; and
    • includes sufficient information to identify the qualifying disclosure; and
    • the extent of the information disclosed in the emergency disclosure is no greater than is necessary to inform the journalist or member of Parliament of the substantial and imminent danger.

Before making an emergency disclosure, it is important that an eligible whistleblower understands the criteria for protection under the relevant legislation. Eligible whistleblowers should obtain independent legal advice prior to making any disclosure.

4.6.3 Public Interest Disclosures

‘Public interest disclosures’ also qualify for protection. These can be made to journalists and members of Parliament but only if the eligible whistleblower complies with the following strict requirements:

• • the eligible whistleblower must have first made a qualifying disclosure to ASIC, APRA, the ATO (for tax matters) or a prescribed Commonwealth authority;
  • at least 90 days must have passed since the report to ASIC, APRA , the ATO (for tax matters) or a prescribed Commonwealth authority was made;
  • the eligible whistleblower does not have reasonable grounds to believe that action is being or has been taken to address the matters to which their original qualifying disclosure relates.
  • the eligible whistleblower has reasonable grounds to believe that reporting their concerns to a journalist or parliamentarian would be in the public interest;
  • the eligible whistleblower gave notice to the body to which the qualifying disclosure was made that states:
    • that they intend to make a public interest disclosure; and
    • includes sufficient information to identify the qualifying disclosure; and
    • the extent of the information disclosed in the public interest disclosure is no greater than is necessary to inform the journalist or member of Parliament of their concerns.

Before making a public interest disclosure, it is important that an eligible whistleblower understands the criteria for protection under the relevant legislation.

Eligible whistleblowers should obtain independent legal advice prior to making any disclosure.

4.6.4 Anonymous Disclosures

An eligible whistleblower can choose to make a disclosure anonymously and to remain anonymous over the course of the investigation and after the investigation is finalised. They may also decide not to answer questions that they feel could reveal their identity at any time, including during follow-up conversations. For example, they may do so because of concerns about their identity becoming known. If such concerns exist, an eligible whistleblower may prefer to adopt a pseudonym for the purposes of their disclosure (not their true name) – or to create an anonymous email address to submit their disclosure to an Authorised Recipient. Regardless, anonymous disclosures are still capable of being protected under the APPI Whistleblowing Policy.

Reporting anonymously may hinder APPI’s ability to fully investigate a reported matter. For this reason, APPI encourages anonymous eligible whistleblowers to maintain ongoing two-way communication with us (such as via an anonymous email address), so that we can ask follow-up questions or provide feedback.

5. BREACH OF THE APPI WHISTLEBLOWING POLICY

5.1 APPI takes contraventions of these protections very seriously and will take disciplinary action against anyone for doing so. If an eligible whistleblower has any particular concerns about this, they can raise them with an Authorised Recipient. Civil and criminal sanctions may apply for breaches of these protections.

5.2 Any breach of the APPI Whistleblowing Policy may be regarded as misconduct and may result in disciplinary action (up to and including dismissal where relevant).

5.3 A breach of the APPI Whistleblowing Policy may also amount to a civil or criminal contravention under the Australian whistleblower protection laws (in particular, the regime contained in the Corporations Act and the Taxation Administration Act), giving rise to significant penalties.