Whistleblowing Policy
Whistleblowing Policy
1. Introduction
1.1 Purpose of the policy
At Sonnel, we aim to be a business that is always values-based and ethical in its conduct. We also aim to be an inclusive organisation where every voice is heard and valued, and where people can speak up about their concerns. We encourage open dialogue and actively support it, believing that listening contributes to a safer, more effective, and positive environment for everyone.
This policy is designed to encourage people who are aware of wrongdoing at Sonnel to speak up safely. The policy should be read alongside Sonnel’s Code of Conduct and Privacy Policy, which set out related expectations for Sonnel’s team members and the criticality of protecting sensitive information.
People who speak up may be entitled to protections that the law gives to ‘whistleblowers’ under the Corporations Act 2001 (Cth) (Corporations Act) or the Taxation Administration Act 1953 (Cth) (Tax Act). You will be a Protected Whistleblower if you report specific kinds of danger, malpractice, bribery, corruption, or other illegal or systemically poor conduct. The law will protect you from being victimised as a result of your disclosures.
If you suspect any serious wrongdoing or legislative breaches, you can file a whistleblowing report following the steps in this policy. You can report to one of our trained internal people if you wish. We have also established a secure external mechanism through which you can raise concerns either anonymously or using your name: our secure whistleblowing platform, Elker.
1.2 About this policy
This policy is not intended to be contractual in nature, but sets out useful information and explains procedures. If you are an employee or contractor of Sonnel, then you need to comply with the directions contained in this policy.
It may be appropriate for Sonnel to depart from this policy in serious circumstances (such as, if there is a risk to a person’s life or safety). Sonnel expects managers to document any departures from policy and report them to the Board. The substantive protections afforded to whistleblowers under this policy and the law cannot be varied.
2. When are you a Protected Whistleblower?
You are eligible to be a Protected Whistleblower if you are:
- a current or former director or other officer of Sonnel or any associated entity;
- a current or former team member;
- a contractor or supplier, or one of their employees (paid or unpaid); or
- the spouse, relative or dependant of a person referred to above.
You will be entitled to whistleblower protections under the law (that is, you will be a Protected Whistleblower) if you are an eligible person and have made a Protected Disclosure:
- about one of the types of wrongdoing set out in the Corporations Act or Tax Act (see section 3 below); and
- to an Eligible Recipient (see section 6 below).
3. What kind of disclosure is protected?
A Protected Disclosure (also known as a ‘Disclosable Matter’) under the Corporations Act is a disclosure of information that the whistleblower has reasonable grounds to suspect concerns:
- misconduct; or
- an improper state of affairs or circumstances, in relation to Sonnel (or a related body corporate).
This includes (but is not limited to) if the whistleblower has reasonable grounds to suspect that Sonnel (or a related body corporate), or any of its officers or employees, has engaged in conduct that:
- is an offence under, or contravention of a provision of any of the following legislation (or any instrument under them):
- Corporations Act 2001;
- Banking Act 1959;
- Insurance Act 1995;
- Life Insurance Act 1995;
- National Consumer Credit Protection Act 2009;
- Australian Securities and Investments Commission Act 2001;
- Financial Sector (Collection of Data) Act 2001;
- Financial Accountability Regime Act 2023; and
- Superannuation Industry (Supervision Act) 1993;
- is an offence against any other Commonwealth law punishable by 12 months’ or more imprisonment; or
- represents a danger to the public or the financial system.
For example, without limiting the examples listed below, a disclosure is likely to be a Protected Disclosure under the Corporations Act if the disclosed information reveals:
- illegal conduct, such as theft or violence;
- fraud or misappropriation of funds;
- financial irregularities;
- risk to public safety;
- modern slavery within our supply chain;
- risk to the company’s financial stability; or
- systemic misconduct affecting company culture, such as widespread bullying or harassment.
A Protected Disclosure under the Tax Act is a disclosure of information that the whistleblower considers may assist the Commissioner for Taxation to perform his or her functions or duties under a taxation law in relation to Sonnel or a relevant associate of the entity.
4. Personal work-related grievances
A ‘personal work-related grievance’ (as defined under the Corporations Act) will not qualify as a Protected Disclosure under the Corporations Act unless it has significant implications for Sonnel that do not relate to you, and:
- concerns conduct (or alleged conduct) referred to in section 3 above; or
- concerns victimisation or threatened victimisation to you, as outlined in section 8 below.
Personal work-related grievances include, but are not limited to:
- interpersonal conflicts between employees;
- transfer or promotion decisions;
- terms and conditions of employment;
- decisions about hiring or termination; and
- performance management issues.
In some unique circumstances, a personal work-related grievance may also be eligible to be a Protected Disclosure. Some examples of a personal work-related grievance which may qualify for whistleblower protections include if:
- it includes information about misconduct that has implications beyond your personal circumstances;
- Sonnel has breached employment or other laws punishable by imprisonment for a period of 12 months or more, or has engaged in conduct which endangers the public; or
- you are victimised for making a disclosure.
If you are unsure whether your concern is a workplace grievance or a Protected Disclosure, we encourage you to report it anyway. We’ll help you determine the right pathway and you won’t be penalised for reporting in good faith, even if your report doesn’t qualify as a Protected Disclosure.
The process for reporting a Protected Disclosure is outlined in section 6 of this Policy. If it is not a Protected Disclosure, then the process for lodging your grievance is set out at https://sonnel.elker.com/report. No matter whether your report is a Protected Disclosure or another kind of grievance, Sonnel will always treat your matter confidentially and can offer support, guidance, advice and problem-solving assistance.
5. Status of legal advice and whistleblowing
Understanding whistleblowing protections can be complex. Any discussions with a legal practitioner about whistleblowing matters are protected by law, even if the lawyer ultimately determines that your disclosure does not qualify for protection.
6. Making a Protected Disclosure
6.1 Making a disclosure directly to Sonnel
At Sonnel, we have authorised Resolve Advisors to receive whistleblowing disclosures through the Elker Platform. Resolve Advisors is an independent organisation that works through the (online) Elker system to deliver this whistleblower solution. You can disclose to Resolve Advisors either anonymously or using your name at: https://sonnelwb.elker.com/report. You can read more about this under 6.3.
Under the legislation, members of Sonnel’s Executive Leadership Team and its directors and auditors are also Eligible Recipients for Protected Disclosures.
However, we encourage you to use the Elker platform where possible to ensure your report is handled by trained specialists and to enable your confidentiality if you opt to report anonymously.
We aim to assess all Protected Disclosures and, if appropriate, investigate with the objective of gathering evidence relevant to any allegations made in the Protected Disclosure. We also aim to keep you informed about the progress of the investigation and to communicate the findings/outcome to you in writing. Sonnel may obtain legal advice in relation to a Protected Disclosure at any time.
Whether reported anonymously or not, we may seek additional information from you as we manage the investigation. If you choose to report anonymously, any correspondence will be sent through the Elker platform, so we encourage you to monitor the platform after you make your report for any updates or further questions or clarifications that we may need.
6.2 Making a public or emergency disclosure
Under whistleblowing legislation, you may also be able to make public interest and emergency disclosures first to the Australian Securities and Investments Commission (ASIC) and the Australian Prudential Regulation Authority (APRA), and subsequently to parliamentarians or journalists.
There are very specific rules about these kinds of disclosures, and making a public disclosure without meeting ALL requirements can result in loss of protections and potential legal liability.
We strongly recommend you seek independent legal advice before taking this step.
6.3 Making a disclosure under the Tax Act
Matters related to Sonnel’s tax reporting and lodgement, such as fraudulent or deceptive tax reporting or other such malfeasance, could result in a Protected Disclosure under the Tax Act. In these situations, you could disclose to any of the Eligible Recipients listed in section 6.1 or section 6.2 of this policy, or, alternatively, to Sonnel’s registered tax agent or the Chief Financial Officer, as the individual who has functions / duties related to Sonnel’s tax affairs – unless of course that person is involved in the matters you are disclosing.
6.4 Making a disclosure using Sonnel’s external platform
Elker is our secure external reporting platform. Elker ensures accurate documentation and protects anonymity. Elker allows you to:
- report anonymously or with a name at any time: once you start your report, you can upload files, save it as a draft to complete later and submit it whenever you are ready; and
- chat safely: once your report is submitted, you can chat with your chosen contact, whether anonymous or named, who will provide support and advice on the platform.
While we fully support anonymous reporting, please be aware that providing your identity (which will be kept confidential) may assist with the investigation as we can seek clarification if needed. If reporting anonymously, please check the portal regularly using your secure access key for any requests for additional information. Save all documentation, including your access key and any communications.
The Elker platform:
- guides you through the reporting process;
- provides a secure tracking number for your report;
- enables anonymous reporting;
- allows secure two-way communication if more information is needed; and
- allows you to monitor your report’s progress through a personal login.
Even if your report doesn’t qualify as a Protected Disclosure, the person receiving it will guide you to an appropriate pathway.
You can access the Elker portal here: https://sonnelwb.elker.com/report.
Information about your data protection is available under the FAQs on the platform. You can read more about Elker at elker.com. Our trust and platform security protocols are available at elker.com/trust-security.
6.5 Support for internal or external disclosures
Any questions or support involving a Disclosure, either before or after reporting, can be directed to the Chief Risk Officer, who is the owner of this Policy.
7. What information should you include in a Protected Disclosure?
When making a Protected Disclosure, we request that you provide enough details to assist the Eligible Recipient to determine the best course of action. This will be included in the Elker platform. It asks for information, such as:
- the specific nature of the misconduct or state of affairs that concerns you;
- the details of the person/s you think engaged or is engaging in any relevant conduct;
- when and where relevant events occurred (for example, dates and times);
- your understanding of the relevant conduct;
- details of anyone else who might be able to verify your disclosure;
- details of anyone else aware of or involved in the conduct or events;
- if you have any concerns about possibly being victimised, and if so by whom.
8. Protections we afford you
8.1 Protection of identity and confidentiality
You can choose to remain anonymous while making a disclosure, over the course of the investigation and after the investigation is finalised. You can refuse to answer questions that you feel could reveal your identity at any time, including during follow-up conversations. Even if you wish to remain anonymous, you can maintain ongoing two-way communication with Sonnel through the Elker channel, so Sonnel can ask you follow-up questions or provide feedback.
If you have chosen to reveal your identity when making a Protected Disclosure, the Eligible Recipient may ask for your consent to disclose your identity and/or information that might lead to your identification in dealing with your Protected Disclosure. For example, this might assist with an investigation.
If you choose not to give consent, then the Eligible Recipient is only permitted to disclose your identity:
- to ASIC, APRA (or to the Commissioner in relation to a tax matter under the Tax Act) or the Australian Federal Police;
- to a legal practitioner to obtain advice or legal representation in relation to the operation of the legislation; or
- in limited circumstances required by law, for example, where ordered by a Court in legal proceedings.
It is a breach of the legislation for the Eligible Recipient to reveal your identity to any other person without your consent.
If reasonably necessary, information that does not reveal your identity may be disclosed to investigate your Protected Disclosure.
We will keep your identity confidential if you choose to identify yourself. This is done by anonymising any investigation activities, restricting those involved in the investigation, limiting any awareness of the disclosure and by securing any details connected to the disclosure and the investigation. We will also ensure you are not prejudiced or targeted for making a report if you choose to identify yourself.
8.2 Other protections
The Corporations Act and the Tax Act confer a number of protections on whistleblowers who make a Protected Disclosure, breach of which is an offence under the relevant legislation and a breach of this policy.
Prohibition of victimisation
‘Victimisation’ is what happens if a person is subjected to detriment as a result of:
- making a Protected Disclosure; or
- someone else’s belief that the person has made or will make a Protected Disclosure.
For example, relevant ‘detriments’ can include harassment or intimidation, termination of employment, injury in employment, physical violence, psychological harm, and/or damage to reputation or property.
Victimisation is strictly prohibited under law and by Sonnel. If you feel you’re being victimised in any way, report it promptly via Elker (which, again, can be done anonymously) or to the Chief Risk Officer. Victimisation claims will be investigated and addressed promptly.
Protections under the legislation
A Protected Whistleblower has additional protections under the relevant legislation including that:
- the Protected Whistleblower is not subject to any civil, criminal or administrative liability (including disciplinary action) for making a Protected Disclosure;
- no contractual or other remedy can be enforced, and no contractual or other right can be exercised against a Protected Whistleblower on the basis of the Protected Disclosure;
- if the Protected Disclosure is made to ASIC, APRA (or to the Commissioner in relation to a tax matter referred to in section 6.5) or is a public interest/emergency Protected Disclosure (see section 6.2), then the information is not admissible in criminal proceedings or for the imposition of a penalty against a Protected Whistleblower (other than in respect of the falsity of the information); and
- a Protected Whistleblower may be entitled to compensation for victimisation. Other remedies may also be available depending on the type of detriment suffered, for example, a Court may grant an injunction to stop victimisation, require an apology to be given, or to re-instate a Protected Whistleblower who has been victimised by termination of employment.
Note: Some of the protections referred to this policy might not be available to you, if you are found to have been involved in wrongdoing (such as, knowingly giving false information).
8.3 Support
If you have concerns about your work environment or your safety when you make a Protected Disclosure (or at any time after making the Protected Disclosure) then you should reach out to our external independent service Resolve, through Elker, or any member of our ELT. They will discuss appropriate strategies with you to manage any challenges arising from the Protected Disclosure or the investigation.
8.4 Involvement in wrongdoing or breach of this policy
Sonnel may take disciplinary action against any person if it finds that they have:
- engaged in wrongdoing which has been identified through an investigation of a Protected Disclosure. The protections under the legislation do not grant immunity for any misconduct that a Protected Whistleblower has engaged in which is revealed in their Protected Disclosure;
- victimised or threatened a Protected Whistleblower;
- disclosed information in breach of whistleblower protections;
- lied or knowingly given false evidence in connection with a Protected Disclosure; or
- otherwise acted in a manner which is inconsistent with the terms of this policy.
9. Governance
This policy is owned by the Chief Risk Officer and is overseen by Sonnel’s Board of Directors. The Board reviews this policy at least bi-annually and at any point that there are material updates in the intervening review period.
The Board monitors the effectiveness of this policy through reporting which is presented at least half-yearly by the Chief Risk Officer. This reporting will set out the number of Protected Disclosures and the status of any investigations. The reporting will also disclose the number of escalations to Elker which are not deemed to be Protected Disclosures.
The details of the investigation reporting are anonymised so as not to disclose or allow the inference of any identifying details of the individual who made the disclosure. Reporting on investigations will include the timeliness and duration of investigations, in order to inform the effective operation of the Elker platform and Sonnel’s own investigation capabilities and capacity. The reporting will also inform the effectiveness of Sonnel’s overall escalation mechanisms, through Elker, through internal whistleblower reporting and through other channels.
If a Protected Disclosure is about, or involves, any member of the ELT, the Board will be made aware of the Protected Disclosure.
10. Need more information?
This policy is available to Sonnel’s officers and employees on our internal intranet. We aim to provide training to all new starters, and whistleblowing updates to all staff from time to time.
Contact: Scott Saunders, Chief Risk Officer – [email protected]
| Contact People | Chief Risk Officer, or any member of the Executive Leadership Team or through the Elker platform |
| Version Number | 1.1 |
| Review Details | This policy was last updated on 9 July 2026 |
| Policy Owner | Chief Risk Officer |
| Review Cycle | This policy will be reviewed:
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