At Fishbowl we have a whistleblower policy in place to eliminate improper conduct in the workplace.

The policy supports and provides a safe and confidential environment for employees, including contractors, consultants, volunteers and former employees as well as their spouses, dependents, and other relatives, and anonymous disclosures to report wrongdoing, without fear of victimisation, reprisal, dismissal or discriminatory treatment.

Fishbowl is committed to maintaining ethical and honest behaviour in the workplace. If an employee genuinely believes in good faith and on reasonable grounds that wrongdoing has occurred, they are encouraged to report this. In reporting wrongdoing, employees will not be disadvantaged or victimised. Fishbowl will endeavour to protect all employees who are making genuine reports of wrongdoing.

Wrongdoing can include but is not limited to dishonest, unethical, fraudulent or corrupt behaviour, accepting or offering bribes, payments or other benefits, committing fraudulent activities, conduct causing damage to the reputation of Fishbowl, breach of any legislation or regulation (including theft, drug sale and/or use and violence), breach of internal policies, inappropriate behaviour relating to accounting and audit matters, concealment of wrongdoing, unsafe work practices and/or behaviour that creates risk to health and safety and any other conduct, deliberate or otherwise, that may cause material financial or non-financial loss to Fishbowl.

Employees are encouraged to report any wrongdoing that is in breach of the Whistleblower or other Company policies as well as the Company values.

Reports of suspected wrongdoing can be made using the following anonymous reporting link.

Whistleblower complaints will be treated with complete confidence. Fishbowl’s People and Culture team will handle all whistleblower complaints confidentially and in line with the Corporations Act 2001, except for complaints relating to the People and Culture team, which will otherwise be managed by the CEO.

Reports of wrongdoing should be in writing and where possible include, as appropriate, the following: the alleged breach, the person/persons alleged to be responsible for the breach, facts which have led there to be a belief that a breach has occurred, and further evidence that would support/substantiate the claim.

Anonymous reports will be accepted under this policy and can be made directly with the People and Culture team or the CEO. Fishbowl cannot guarantee anonymity in all cases as complaints will be handled consistent with the law and reporting requirements, however the identity of the individual making the claim will be kept confidential to the extent practicable permitted by law. Certain anonymous reports have limitations that may inhibit finding a resolution as proper and appropriate investigation may not occur due to an inability to gather additional information, and this may impact Fishbowl’s ability to report back on progress and the outcome.

Any wrongdoing reported may be investigated using the investigation procedure outlined below. Any employee that reports wrongdoing must maintain confidentiality at all times.

1. The following disclosures are protected: misconduct or an “improper state of affairs or circumstances” regarding any of the entities covered by the laws or their related bodies corporate, conduct that breaches the Corporations Act 2001 or conduct that breaches the ASIC Act or a range of specified insurance, life insurance and superannuation statutes, conduct that relates to an offence against any law of the Commonwealth which is punishable by imprisonment for 12 months or more, or a danger to the public or the financial system.

2. Upon receiving a report of a breach, Fishbowl will assess whether the claim is genuine, factual and unquestionably credible. If the claim is deemed to be in breach of this policy, Fishbowl will nominate an internal officer, or an external consultant to investigate.

3. All matters raised will be treated in a confidential, secure and sensitive manner and investigations will be conducted in accordance with the principles of procedural fairness and natural justice, this includes ensuring the objectivity of the investigator, following a fair and proper procedure, acting on the basis of logical proof and evidence when making a decision, informing an individual of claims made against them and allowing them an opportunity to be heard and respond.

4. The process for investigation involves defining the key issues to be investigated, defining the scope of the investigation including relevant questions to be asked, ensuring the scale of the investigation is proportionate to the seriousness of the allegation and ensuring sufficient and appropriate resourcing, analysing initial information and evidence relating to the claim, interviewing any individuals named to be in breach of the policy, interviewing relevant witnesses, obtaining and examining further evidence, making a final determination as to whether the breach can be substantiated based upon findings of fact and evidence and developing a report outlining the allegations, relevant findings, the conclusion reached and recommendations to address the wrongdoing.

5. Interviews conducted during the investigation may be, with authorisation, taped and notes recorded. Employees reporting wrongdoing will be required to assist in the investigation process by providing any information necessary to assess the claims.

6. Any employee found to have engaged in wrongdoing or making a vexatious complaint may be subject to disciplinary action, up to and including termination of employment.

Please note this policy does not replace procedures regarding discriminatory, harassing or bullying behaviour. The protections also do not extend to ‘personal work-related grievances’, (that is grievances by an employee relating to their employment or former employment which impacted them personally).