Whistleblower Policy - Deloitte

1 0 Whistleblower PolicyDecember 2019 Whistleblower Policy | Introduction1 IntroductionIntroduction11 Introduction4 Purpose4 Background4 Who is a Whistleblower ?4 What is Reportable Conduct?4 Accessibility of Policy5I need further information about this Policy5 Monitoring and review of Policy52 How do I make a Whistleblower Report?6 When can I make a Whistleblower Report?6 How can I make a Whistleblower Report?6 Identity Protection73 What protection will I have as aWhistleblower?8 The Whistleblower Protection Officer8 Detrimental Conduct is not tolerated8 False or misleading disclosures84 How will my matter be investigated?9 Who will assess or investigate my matter?9 How will my Whistleblower Report be reviewed by Deloitte ?

2 9 What is the investigation process?9 Fair treatment of the individuals mentioned in the Whistleblower Report 9 What happens after an investigation?95 What support do I have?10 Employee Assistance Program10 Raising concerns about actions taken by Deloitte106 Definitions112 This Policy sets out how Deloitte willsupport you so that you can safelyexpress your concerns, know who tocontact, how to make a report and theprotections available to PolicyWhistleblower Policy | Introduction3 Eligible current and former partners, directors, officers, company secretaries, employees, secondees, contractors,suppliers (or their employee or subcontractor) and volunteers. It also applies to relatives, dependents orspouses of any of these Reportable Conduct (anonymously if you choose).

3 Illegal conduct, fraud, money laundering, offering oraccepting a bribe, financial irregularities, failure tocomply with, or breach of, legal or regulatoryrequirements, and engaging in or threatening toengage in Detrimental there are reasonable grounds to suspectmisconduct or an improper state of affairs; anoffence or contravention under commonwealthlaw or a danger to the public or financial Speak UpCall 1800 931 215 Protection as a Whistleblower under the relevant lawsWhistleblower Policy | Introduction41 IntroductionPurposeAt Deloitte , we are committed to the highest levels ofethics and integrity in the way that we do business. Weunderstand that this is crucial to our continued successand Shared Values,Principles of Business Conduct, andpolicies guide our everyday conduct.

4 We have aprofessional responsibility to speak up and reportunethical s Whistleblower Policy ( Policy ) is an importantelement in detecting corrupt, illegal or other undesirableconduct. Deloitte strongly encourages you to speak up ifyou suspect or witness any matters of concern. Deloittewill take all reports made under this Policy Policy describes the protections available towhistleblowers, what matters are reportable, how youcan report your concerns without fear of Detriment, andhow Deloitte will support and protect have developed this Policy , having regard to therelevant legal requirements and current best practicesrelating to the protection of whistleblowers in theCorporations Act 2001 (Cth), Taxation AdministrationAct 1953 (Cth) and ASIC s Regulatory Guide 270 Whistleblower Whistleblower Management Plan (Plan) supportsour Whistleblower Policy .

5 It provides further informationon how Deloitte will implement the Policy , includingguidance for the various roles involved in managingWhistleblower Reports, including the: Whistleblower Report Officer (WRO) Whistleblower Investigation Officer (WIO) Whistleblower Protection Officer (WPO) Whistleblower Committee (WB Committee); and Whistleblower Policy Owner (WB Policy Owner).Unless expressly stated otherwise, all capitalised termsin the Policy have the meaning given to them inSection 6 Definitions .Who is a Whistleblower ?A Whistleblower is someone who discloses ReportableConduct (as defined in Section 6) under this Whistleblower can be a current or former partner,director, officer, company secretary, Employee, supplierof goods or services to Deloitte (such as a secondee,contractor, and consultant) or a volunteer.

6 It alsoapplies to relatives, dependents or spouses of any ofthese people (Eligible Whistleblowers).Who is not covered?This Policy does not apply to third parties (other thanEligible Whistleblowers) including without limitationcustomers of Deloitte . Customers with complaintsshould refer to ourComplaints the right thingWe expect everyone who works for Deloitte to complywith our Principles of Business Conduct, our policiesand procedures, professional standards, lawsand also have a responsibility to speak up using one ofthe many channels available within the Firm when yoususpect something does not look or feel encourage you to consider talking to your trustedpartner, manager, coach or Talent representative, or ifexternal to Deloitte your Deloitte contact.

7 We wouldrather hear your concerns directly so that we canresolve them you make a Whistleblower Report pursuant to thisPolicy, we have a responsibility to protect you, includingnot disclosing your identity (unless required orpermitted by law) and making sure you are not subjectto Detrimental is Reportable Conduct?Reportable Conduct is anything that you havereasonable grounds to suspect, in relation to Deloitte ,is: misconduct , or an improper state of affairs orcircumstances; conduct that constitutes a contravention of lawsspecified in the Whistleblower Laws or otherCommonwealth laws that are punishable byimprisonment for a period of 12 months or more; or conduct that represents a danger to the public orthe financial Policy | Introduction5 Examples of Reportable Conduct include but are notlimited to: illegal conduct, such as theft, violence or threatenedviolence, and criminal damage against property; fraud, money laundering or misappropriationof funds; offering or accepting a bribe.

8 Financial irregularities; failure to comply with, or breach of, legal orregulatory requirements; and engaging in or threatening to engage in DetrimentalConduct against a person who has made adisclosure or is believed or suspected to have madeor be planning to make a Conductexcludes personal work-relatedgrievances as described work-related grievancesA personal work-related grievance is a report ofbehavior that has implications for the discloserpersonally and does not have significant implications forDeloitte (that do not relate to you). Examples include: an interpersonal conflict between you and anotherEmployee, or a decision relating to your employment orengagement, such as a transfer, promotion, ordisciplinary work-related grievances do not qualify forprotection under the Whistleblower Laws or this work-related grievances must be raised withyour Partner, Coach or Talent of PolicyThis Policy is available to all current partners andEmployees internally on the Ethics and Integrity HubDAIS webpage.

9 Other Eligible Whistleblowers can accessthis Policy on the Deloitte external need further information about this PolicyEmployees can seek confidential information on theoperation of this Policy and how a disclosure will behandled, without making a disclosure, by contacting theOffice of General Counsel, Ethics Officer and/or theConduct , if you require legal advice with respect toyour obligations under this Policy or the WhistleblowerLaws, then you must contact an external lawyer (notthe Deloitte in-house legal team).Monitoring and review of PolicyThe Policy will be periodically reviewed by the WB PolicyOwner. The Board will provide oversight of the Policy | How do I make a Whistleblower Report?

10 62 How do I make a WhistleblowerReport?When can I make a Whistleblower Report?Before making your Whistleblower Report you shouldsatisfy yourself that you have reasonable grounds tosuspect Reportable Conduct. Reasonable grounds tosuspect is based on objective reasonableness of thereasons for the suspicion. In practice, a mere allegationwith no supporting information is unlikely to reachthat , a Whistleblower does not need to provetheir allegations. In addition, the disclosure can stillqualify for protection even if the disclosure turns outto be can I make a Whistleblower Report?Contact Deloitte Speak Up, Deloitte s independent,anonymous and secure Whistleblower service deliveredby NAVEX Global, Inc (NAVEX).