Whistleblower Policy

Astley Care is dedicated to fostering a safe environment for whistleblowers to report suspected misconduct or wrongdoing. We are committed to ensuring that all staff (including volunteers), clients, and all stakeholders feel secure and supported when raising concerns. By encouraging a ‘speak-up’ culture, we emphasize robust protection against retaliation and reaffirm Astley Care’s promise to address all concerns fairly and without reprisal. This policy details the measures Astley Care has in place to safeguard and support whistleblowers, in compliance with the Corporations Act 2001 (Cth) and the Aged Care Act 2024.

What is a Whistleblower Disclosure?

A whistleblower disclosure is when you report something you reasonably believe may be misconduct or serious wrongdoing. This could include:

• unsafe or poor-quality care
• neglect or abuse
• fraud, dishonesty, or serious breaches of the law
• conduct that does not meet the standards of the Aged Care Act 2024.
• Unlawful Behaviours

You may make a disclosure either verbally or in writing, and you have the option to remain anonymous if you wish. It is not necessary to provide proof; you only need to have reasonable grounds to suspect that the information concerns conduct that may breach a provision of the Aged Care Act.

In general, whistleblower protections do not extend to reports about staff grievances such as workplace harassment, bullying, discrimination, or general complaints. Similarly, client complaints regarding dissatisfaction with services, staff, or care outcomes, including routine issues in aged care like service quality, delays, or poor communication, are handled through other established channels. These issues will be addressed according to Astley Care’s Internal Grievance, Feedback and Complaints, and Incident Management procedures. However, if you believe your concern cannot be addressed through these existing avenues, if the matter is particularly sensitive, or if you are unsure whether the conduct constitutes wrongdoing under the whistleblower policy, you may choose to use the whistleblower disclosure process to report your concerns.

Who can I make a disclosure to?

You can make a whistleblower disclosure to any of the following people:

• a register provider of funded aged care services, such as Astley Care
• a responsible person for a registered provider (e.g. a Board member at Astley Care)
• an aged care worker or a registered provider (e.g. a worker at Astley Care)
• an Appointed Commissioner or a member of the staff of the Aged Care Quality and Safety Commission (ACQSC)
• the System Governor, or an official of the Department of Health, Disability and Ageing
• an independent aged care advocate (e.g. OPAN)
• police officer

How to make a whistleblowing disclosure to us

You can make a whistleblower disclosure in any way that works for you, and the below table outlines the avenues available to current Astley Care staff (refer to section in orange) and all other stakeholders such as Astley Care clients, families and carers, former staff, associated providers, business partners, etc. (refer to section in blue).

Reporting in person, in writing (email, or post), or via phone

1. Phone: call 08 6500 8200
2. Send us a letter addressed to P.O. Box 645, Gosnells WA 6990. Marked

confidential and addressed to the privacy officer

3. Send us an email to: privacy@astleycare.com.au
4. In person: Talk to a Team Leader or Line Manager at Astley Care: 23 Astley St,

Gosnells WA 6110

Current Staff

Astley Care’s policies and procedures promote reporting and raising concerns

with your manager or via the People and Culture team. Refer to the relevant

Astley Care policies, such as the Grievance Management, Work Health &

Safety, Astley Care Health and Safety Handbook, and Astley Care Employee

Handbook, and report/escalate via the Responsible Manager or the People

and Culture team. Where this is not possible, and you believe an issue cannot

be resolved through these existing avenues, and/or if the matter is

particularly sensitive, you can raise your concern via Whistle Blowing Services

(WBS), as described below.

Reporting via Whistle Blowing Service (WBS) in writing (online platform) or verbally (via phone)

1. Via Phone You can contact 24/7 on ‘1300 687 927’.

Online platform: Click on the provided link and ‘select’ the WBS tile and

‘click’ on the ‘Make a Report’ button, and you will be redirected to the new page

where you need to:

• enter ‘ASTLEY’ in the ‘Unique Key’ field;
• enter ‘ASTLEY2025’ in the ‘Client Reference Number’.
• Click on ‘next’ and follow the prompts

Astley – Whistleblowing Service

Other Stakeholder’s:

Clients, families, carers, former staff, associated providers, business partners, etc.

Reporting via Whistle Blowing Services (WBS) in writing (online platform) or verbally (via phone).

Online platform: Go to Astley Care Website, add the link, and ‘select’ the

WBS tile or go directly to WBS link. ‘Click’ on the ‘Make a Report’ button, and

you will be redirected to the new page where you need to:

• enter ‘ASTLEY’ in the ‘Unique Key’ field.
• enter ‘ASTLEY2025’ in the ‘Client Reference Number’.
• Click on ‘next’ and follow the prompts

Astley – Whistleblowing Service

Phone: You can contact via phone 24/7 on ‘1300 687 927’.

To ensure robust protection for whistleblowers, including facilitating communication with anonymous whistleblowers, Astley Care engages Whistle Blowing Services (WBS), an external and independent service provider specially trained in managing sensitive issues that arise in whistleblower contexts. This arrangement guarantees that disclosures related to protected matters are received impartially and treated with the utmost confidentiality. Reports can be made either verbally or in writing, with the option to remain anonymous or provide their identity.

ANONYMITY

While we encourage all individuals to disclose their identity when raising a concern, to assist in gathering further information and for investigation purposes, whistleblowers can choose to report anonymously (i.e. not reveal their identity). It is however highlighted that anonymous whistleblowers must be aware that anonymous reporting may affect the outcome of the investigation, as evidence may be more difficult to substantiate.

HOW WILL WE INVESTIGATE DISCLOSURES?

All disclosures received will be taken seriously and we will assess the information provided and take appropriate steps to investigate or manage the issue, in line with our internal processes. In carrying out our investigation, we will ensure the disclosures are investigated in a fair, objective, confidential and transparent manner in line with the principles of natural justice included.

• Acknowledging and responding to disclosures in a timely manner. The typical timeframe

for resolution will be approximately 30 to 60 working days.

• Investigations are conducted by qualified, appropriate and impartial staff
• Evaluating each disclosure thoroughly
• Collecting evidence to substantiate or refute claims
• Taking appropriate corrective action as warranted by the investigation
• Providing regular feedback to those involved in the disclosure while protecting their

privacy and in accordance with Astley Care Privacy Policy

If the feedback provided does not meet the criteria for a whistleblower disclosure, it will be managed according to Astley Care’s Feedback and Complaints management processes and systems. Conversely, if a complaint or feedback is later found to meet the requirements of a qualifying disclosure, it will be managed under the whistleblower regime. Whistleblowers retain the right to choose for their disclosure to be treated as a complaint or feedback rather than under the whistleblower regime and may withdraw their disclosure at any time.

HOW WILL WE SUPPORT & PROTECT WHISTLEBLOWERS?

We will take all reasonable steps to support whistleblowers by:

• Providing information to the whistleblower about their rights and the expected process for the disclosure
• Fully Maintaining the confidentiality and anonymity of all whistleblowers possible (with some exceptions such as where it is necessary to share information with the ACQSC or a lawyer to prevent a serious threat to a person or people)
• Facilitating access to counselling, advocacy, legal support or other support services
• Offering temporary relocation or reassignment of duties, where necessary, to protect the well-being and safety of the individual
• Ensuring no disciplinary action is taken against whistleblowers when the disclosure was made with a genuine or reasonable belief regarding misconduct, even when that allegation is incorrect.
• Not tolerating any threats, acts or omissions designed to cause detriment to a whistleblower (or another person) in relation to a disclosure. This includes dismissal or termination, demotion, reputational damage or injury or damage to person or property.
• Ensuring fair treatment of any individual mentioned in the disclosure informed by the principles of natural justice.
• Providing education and training regularly to Astley Care staff on the whistleblower policy and processes
• Maintaining secure record keeping and information sharing processes by:
• storing all paper and electronic documents and other disclosures materials safely and securely
• limiting access to information related to disclosures to those directly involved in managing and investigations disclosures
• keeping all documentation and records for 7 years

Astley Care takes protection from retaliation very seriously and will not tolerate attempts to harm or threaten an individual who makes a disclosure. It’s also important to know that while the law protects people who speak up, it does not protect someone from consequences if they are personally involved in doing something wrong. For example, if the disclosure reveals that the person who reported the concern also took part in serious misconduct, they may still face legal consequences for those actions.

FURTHER INFORMATION

If you require assistance in understanding this policy, require further information or translation of this document in order to understand it, please contact us at privacy@astleycare.com.au.