Whistleblowing Policy

1. Policy Brief and Purpose

Our Whistleblowing company policy outlines our expectations regarding employees’ compliance with our company culture and principles as they apply to Whistleblowing.

2. Scope

This policy applies to all our employees regardless of employment agreement or rank. Company employees are bound by their contract to follow our Whistleblowing Policy while performing their duties. The need for a good corporate governance policy to foster upward reporting in an environment free from recriminations and victimisation is essential if Anywise senior management and the board are to adequately manage risk and cultural issues within the company. We outline the components of our Whistleblowing Policy below.

3. Be Safe

At all times, it is an expectation that all of our team members, regardless of level, responsibilities or authority, will remain safe and endeavour to ensure that others also remain safe.

4. Comply with the law

All employees must protect our company’s legality. They should comply with all environmental, safety and fair dealing laws. We expect employees to be ethical and responsible when dealing with our company’s finances, products, partnerships and public image.

5. Specific considerations

A person is protected as a whistleblower if they are:

an officer or
an employee of a company or
a contractor or their employee who has a contract to supply goods or services to the company.

The Corporations Act restricts any retaliation against a whistleblower and gives them a civil right, including seeking reinstatement of employment. Protection is extensive:

providing qualified privilege against defamation
precluding contractual or other remedies from being enforced, including civil and criminal liability, for making the disclosure. This means that secrecy provisions in employment contracts and the like will not preclude whistleblowing.

To qualify for protection a whistleblower’s revelation must be made to:

ASIC or
the company’s auditor or a member of the audit team or
a director, secretar,y or
senior manager of the company or
another person authorised by the company to receive revelations of this kind. ( e.g. outsourced internal audit functions)

To trigger the provisions of the Corporations Act, the whistleblower must:

Give their name before making the disclosure and
have reasonable grounds to suspect that their revelation indicates the company or an officer or employee has, or may have, contravened the Corporations legislation (which includes both the Corporations Act and the ASIC Act) and act in good faith.

6. Handling revelations from a whistleblower

Under the Corporations Act, Anywise can only pass on the revelation and the identity of the whistleblower (or information that may lead to the identity of the whistleblower) under the following circumstances:

We can pass it on to ASIC, APRA or the Australian Federal Police without asking for the whistleblower’s permission.
We can only pass it on to a third party if the whistleblower has given their consent. This means, for example, that a company secretary cannot pass on the revelation to members of the board or the CEO unless the whistleblower has consented to them doing this. Anywise recommends that whistleblowers make their revelations directly to an appropriate person, such as the chairman of the audit committee of the Board or some other person as required by another regulator or overseas regulatory requirement relevant to the company.

7. Procedures for Anywise

7a. Notices

Whistleblowers are to submit concerns to the company Secretary, Adam Evans. If this is inappropriate, any Senior Manager (Heads) or CEO is to be notified. Failing this, submission to the Board of Directors can be made in writing to:

The Board of Directors - Anywise Consulting Pty Ltd

PO Box 292, Brunswick East, Vic, 3056

7b. Non-Retaliation and Consequences

Anywise strictly prohibits retaliation against any individual who makes a disclosure under this policy in good faith. Retaliation is defined as any adverse action, including but not limited to, termination, demotion, harassment, or a change in work conditions. Any employee found to have engaged in retaliatory behavior will be subject to disciplinary action, up to and including termination of employment, in accordance with Anywise's internal disciplinary procedures. The company is committed to ensuring a safe and supportive environment for whistleblowers and will take prompt and effective action to address any identified retaliation.

7c. Mechanisms for Whistleblower Protection

Confidentiality: All whistleblower revelations will be treated with the utmost confidentiality. Information will be handled on a strict need-to-know basis to protect the identity of the whistleblower and the integrity of the investigation. The identity of the whistleblower will not be disclosed without their consent, unless required by law.
Support and Resources: Anywise will provide support to whistleblowers, which may include offering a safe work environment and accommodations as necessary during an investigation.
Protection from Legal Liability: The company will ensure that no contractual remedies or other legal actions are taken against a whistleblower who makes a disclosure in good faith, in accordance with the Corporations Act.

7d. Communication and Outcome Notification

Anywise is committed to maintaining transparent communication with whistleblowers throughout the investigation process:

Whistleblowers will receive timely updates acknowledging receipt of their disclosure, confirmation when an investigation commences, and progress updates at key stages where appropriate.
Upon completion of the investigation, the whistleblower will be notified in writing of the outcome, including confirmation of any actions taken or the rationale where a matter was not accepted as a formal disclosure.
All communications will respect confidentiality and applicable legal obligations.