Whistleblower Policy Summary

Infomedia is committed to the highest standards of conduct and ethical behaviour in our business activities. The Board of Directors and Executive Leadership Team recognise that any genuine commitment to detecting and preventing illegal, fraudulent, unethical or other undesirable conduct must include a mechanism whereby employees and others can report their concerns freely and without fear of reprisal or intimidation.

The objective of the Infomedia Whistleblower Policy (the Policy) is to:

  • Promote an open and transparent culture within Infomedia.
  • Encourage eligible ‘Whistleblowers’ to report an issue if they genuinely believe a person or persons has engaged in Misconduct.
  • Demonstrate Infomedia’s commitment to a fair workplace and outline the process for reporting and managing reports of Misconduct.
  • Protect individuals who report Misconduct in line with this policy and which they reasonably believe to be corrupt, illegal or unethical on a confidential basis, without fear of reprisal, dismissal or discriminatory treatment.
  • Ensure that matters of Misconduct and/or unethical behaviour are identified and addressed appropriately.

Who qualifies as a Whistleblower?

For the purposes of the Policy, a ‘Whistleblower’ is defined as any current Infomedia employee, director, contractor or consultant who, makes, attempts to make or wishes to make a report in connection with ‘Misconduct’. Eligible Whistleblower’s are encouraged to refer to the Policy when making a disclosure.

What is Misconduct?

‘Misconduct’ includes the following types of behaviours or conduct which should be reported under the Policy:

  • Dishonest, fraudulent, corrupt or unlawful conduct or practices.
  • Misleading or deceptive conduct.
  • Conduct or any proposed conduct, bid, proposal, offer, contract, product or other aspect of Infomedia business that breaches the provisions of any Australian legislation (Commonwealth or State) or in countries Infomedia does business with.
  • Coercion, harassment or discrimination by, or affecting, any member of Infomedia or its affiliates.
  • A breach of Infomedia policies or Code of Conduct.
  • Conduct endangering the health and safety of any person or persons.
  • Any other conduct or act which may cause loss to Infomedia or which may otherwise be detrimental to its interests.

Making the Disclosure

Whilst not intending to discourage Whistleblowers from reporting matters of genuine concern, Whistleblowers must ensure as far as possible, that reports of Misconduct are made in good faith and based on a reasonable belief that Misconduct has occurred.

Eligible Whistleblower’s may wish to discuss the matter informally with their direct line manager or the responsible People & Culture Manager to determine first whether an incident of Misconduct has occurred. Where this is not appropriate, the Whistleblower may wish to report the Misconduct internally by completing and submitting a Misconduct Report Form.

The Policy does not in any way restrict or diminish the right of a Whistleblower to make disclosures directly to relevant regulators.

Whistleblower Investigations

All reports of Misconduct are treated seriously and subject to an investigation with the objective of locating evidence that either substantiates or refutes allegations of Misconduct.

Investigations will be conducted in a manner that is confidential, fair and objective by the appointed independent Whistleblower Investigation Officer. The accused party or parties shall be entitled to a presumption of innocence until the allegations of Misconduct have been fully investigated.

At the end of the investigation, the appointed Whistleblower Protection Officer will report their findings to the CEO (or such other parties as may be appropriate) who will determine the appropriate response.

Protection and Support

Infomedia does not tolerate any instances retaliation or adverse treatment against a Whistleblower acting in good faith.

Information received from the Whistleblower, or that could lead to their identification, will be treated confidentially, and will not be shared unless consented to or required by law.


Infomedia’s Whistleblower Policy will be reviewed periodically by the Audit & Risk Committee. A report will be made to the Board of the outcome of each review and any recommended changes to the Policy.