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 ?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.

2 It also applies to relatives, dependents orspouses of any of these Reportable Conduct (anonymously if you choose)..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. We have aprofessional responsibility to speak up and reportunethical s Whistleblower Policy ( Policy ) is an importantelement in detecting corrupt, illegal or other undesirableconduct.

3 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 . 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).

4 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. 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.

5 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; financial irregularities; failure to comply with, or breach of, legal orregulatory requirements.

6 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. 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).

7 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?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). The service is available24 hours a day through these channels:Contact detailsTelephone 1800 931 215; or Reverse charge / collect call through tothe US number: 5037471838 (PNGstaff ONLY).

8 Onlinesubmission Access via secure web link (Chromebrowser): DeloitteSpeak Up; or Link from theDAIS Ethics & IntegrityHubDeloitte recommends using the Deloitte Speak Upservice to make your Whistleblower Report. WhileDeloitte Speak Up is our preferred channel, you can alsomake a report directly to any WRO, including: The CEO The Ethics Officer The Chief Transformation Officer Business Unit Leaders The Chief Taxation Officer Chair of the BoardIf you make a Whistleblower Report directly to a WRO,they will forward the report to Deloitte Speak Up foraction under this you are making a disclosure concerning the EthicsOfficer, you must report to a WRO other than DeloitteSpeak Up and the WRO will immediately direct yourdisclosure to the CEO for investigation. If you aremaking a disclosure concerning the Executive or Boardof Deloitte , you may report as follows:RoleContactCEO and ExecutiveLeadershipChair of the BoardBoard memberChair of the BoardChair of the BoardDeputy Chair of the BoardThere are other ways you can make disclosures inlimited circumstances, including to a Regulator, or whenmaking an emergency or public interest you make any such disclosure you should seekindependent legal advice to understand the criteria formaking such a should I include in the report?

9 Please provide as much detailed information as possibleso that your report can be useful details include: date, time and location; names of person(s) involved, roles and theirbusiness group; your relationship with the person(s) involved; the general nature of your concern; how you became aware of the issue; possible witnesses; and other information that you have to supportyour I make a Whistleblower Reportanonymously?You can choose to make your disclosure anonymouslyand if so, you will still be protected under theWhistleblower Laws. However, requiring completeanonymity may practically make it more difficult for usWhistleblower Policy | How do I make a Whistleblower Report?7to investigate the issue or take the action we would liketo letting us know who you are, we can contact youdirectly to discuss your concerns which will help usinvestigate the complaint more quickly and can also appoint a WPO to you to assist with anyquestions or concerns that you have about the ProtectionWhere you make a disclosure, your identity (or anyinformation which could identify you) will only beshared where: you provide consent; or Deloitte is permitted, or otherwise required, by , you should be aware that in certaincircumstances the WRO does not need your consent toshare your disclosure if: the information does not include your identity; we have taken all reasonable steps to reduce therisk that you will be identified from the information;and it is reasonably necessary for investigating theissues raised in the Whistleblower Policy | What protection will I have as a Whistleblower ?

10 83 What protection will I have as aWhistleblower?A Whistleblower must make a Whistleblower Reportdirectly to an Eligible Recipient to qualify for protectionsunder the Whistleblower Laws and this Policy . Theseprotections include: Identity protection (refer section 2) Protection from Detriment Compensation and remedies; and Civil, criminal and administrative liability are committed to taking all reasonable steps toprotect you from Detriment as a result of making areport under this Policy and the Whistleblower Whistleblower Protection OfficerWhere you have disclosed your identity to us, we mayappoint a WPO will take steps to protect the interests ofindividuals making reports under this WPO would usually act as the contact point forcommunication with the Whistleblower . A WPO may beassigned to current, identifiable partners Conduct is not toleratedDeloitte does not tolerate any form of DetrimentalConduct taken by any person against the Whistlebloweror any people who are involved in an investigation of aWhistleblower of Detrimental Conduct can include, but arenot limited to: dismissal of an employee or alteration of anemployee s position/ duties to their disadvantage,or negative performance feedback that is notreflective of actual performance harassment, intimidation, or bullying; and threats to cause of actions that are not Detrimental Conductmay, for example, include: managing a Whistleblower s unsatisfactory workperformance, if the action is in line with Deloitte sperformance management framework administrative action that is reasonable to protectthe Whistleblower from takes all allegations of Detrimental Conductvery seriously.