Clean Investor Pty Ltd and its related entities, subsidiaries, affiliates, managed partnerships, trusts, and associated investment structures (collectively referred to as Clean Investor Group) are committed to fostering a culture of integrity, transparency, ethical conduct, regulatory compliance, and strong corporate governance.
The Clean Investor Group values accountability, professionalism, teamwork, and respect. We encourage all officers, employees, contractors, suppliers, and stakeholders to speak up about suspected misconduct, unethical behavior, or improper practices without fear of retaliation or disadvantage.
This Whistleblower Protection Policy establishes a safe, confidential, and supportive framework for reporting concerns and outlines:
When a person is protected for making a disclosure
The protections available to whistleblowers
How disclosures are handled and investigated
The responsibilities of the Clean Investor Group regarding whistleblower matters
This policy applies to all officers, employees, contractors, consultants, and representatives of the Clean Investor Group globally.
Employees and officers operating outside Australia may also be subject to additional local whistleblower laws and regulatory obligations.
2. Who Is Protected Under This Policy?
You may receive protection under this policy if:
You are an eligible whistleblower as described in Section 3
You disclose information relating to matters outlined in Section 4
You report the information to an eligible recipient identified in Section 5
3. Who May Make a Protected Disclosure?
A disclosure may qualify for protection under Australian whistleblower laws if you are or were:
An officer, employee, intern, secondee, or director of the Clean Investor Group
A contractor, consultant, supplier, service provider, or business partner
An employee of a contractor or supplier connected to the Clean Investor Group
An associate of the Clean Investor Group
A spouse, dependent, parent, child, sibling, or relative of any of the above individuals
4. What Can a Protected Disclosure Be About?
Protected disclosures may relate to misconduct, unethical behavior, illegal activities, or an improper state of affairs involving the Clean Investor Group or its representatives.
Disclosures do not need to involve an actual breach of law to qualify for protection.
However, personal work-related grievances that relate solely to an individual’s employment situation are generally not covered unless they involve retaliation, victimization, or misconduct connected to a protected disclosure.
4.1 Examples of Disclosable Matters
Examples of conduct that may qualify for whistleblower protection include:
Fraud, corruption, bribery, or financial misconduct
Money laundering or misappropriation of funds
Breaches of corporate, financial, or tax laws
Criminal conduct or regulatory violations
Unsafe work practices or serious workplace misconduct
Harassment, discrimination, or unethical conduct
Modern slavery, child labor, or human rights violations
Cybersecurity breaches or misuse of confidential information
Conduct posing a danger to the public, environment, or financial system
Retaliation against a whistleblower or person suspected of making a disclosure
Systemic governance failures or serious compliance breaches
4.2 Personal Work-Related Grievances
Examples of personal work-related grievances include:
Interpersonal workplace conflicts
Dissatisfaction regarding compensation or promotion decisions
Performance management concerns
Employment transfer or disciplinary decisions
Workplace disputes unrelated to misconduct or regulatory breaches
These matters should generally be addressed through internal HR or employee grievance procedures unless they involve whistleblower retaliation or broader misconduct concerns.
4.3 Reasonable Grounds for Disclosure
A whistleblower may still receive protection even if the disclosed information later proves incorrect, provided the disclosure was made on reasonable grounds and in good faith.
Knowingly making false or misleading allegations may result in disciplinary action.
5. Who Can Receive a Protected Disclosure?
Protected disclosures may be made to any eligible recipient under applicable whistleblower laws.
However, Clean Investor encourages disclosures to be directed to the designated:
A whistleblower’s identity will not be disclosed unless:
Required by law
Necessary for regulatory reporting
The whistleblower consents
Disclosure is required to obtain legal advice
Disclosure is necessary for investigation purposes while taking reasonable protective measures
7.2 Court and Tribunal Protections
Clean Investor will take reasonable steps to prevent disclosure of a whistleblower’s identity in legal proceedings unless legally required.
Whistleblowers may seek legal protection orders where necessary.
7.3 Protection from Retaliation and Detriment
Retaliation against whistleblowers is strictly prohibited.
Protected individuals must not suffer:
Dismissal or termination
Demotion or disadvantage
Harassment or intimidation
Discrimination or victimization
Financial, reputational, or psychological harm
Threats of retaliation
Clean Investor may implement protective measures where necessary to safeguard whistleblowers.
7.4 Protection from Liability
Eligible whistleblowers are protected from:
Civil liability
Criminal liability
Administrative or disciplinary action
in relation to making a protected disclosure.
However, protections do not extend to misconduct personally committed by the whistleblower.
7.5 Compensation and Remedies
Whistleblowers may seek legal remedies and compensation if they suffer harm due to retaliation or inadequate protection measures.
8. Investigation Process
8.1 Investigation Procedure
When a disclosure is received:
Step 1
The disclosure is referred to the Whistleblower Protection Officer or an independent director where appropriate.
Step 2
An initial assessment determines whether the disclosure qualifies for protection and whether a formal investigation is required.
Step 3
An impartial investigator — internal or external — conducts the investigation fairly, confidentially, and independently.
Step 4
Findings are reported to the Board while protecting whistleblower confidentiality.
Where appropriate, whistleblowers may receive updates regarding investigation progress and outcomes.
8.2 Investigation Timeframes
Investigations will generally aim to conclude within two months, although complex matters may require additional time.
8.3 Ongoing Communication
Anonymous whistleblowers are encouraged to maintain secure communication channels to assist investigations and receive updates.
9. Support and Protection Measures
Clean Investor maintains processes to protect and support whistleblowers, including:
Risk assessments
Workplace adjustments where necessary
Confidential wellbeing support
Access to counseling or support services
Ongoing monitoring against retaliation risks
10. Board Oversight and Reporting
The Whistleblower Protection Officer will provide periodic reports to the Board or delegated committee regarding whistleblower matters, including:
Number and type of disclosures
Investigation status
Actions taken
Resolution outcomes
Response and investigation timeframes
All reporting will maintain confidentiality obligations.
11. Training and Awareness
Clean Investor provides mandatory whistleblower training for:
Officers and directors
Eligible disclosure recipients
Employees and contractors
Training covers:
Whistleblower rights and protections
Reporting procedures
Confidentiality obligations
Handling disclosures appropriately
Prevention of retaliation and detrimental conduct
12. Non-Compliance with This Policy
Breaches of this policy may result in disciplinary action, termination of engagement, regulatory consequences, or legal penalties.
Individuals are encouraged to report concerns regarding non-compliance directly to the Whistleblower Protection Officer or relevant regulatory authorities.
13. Policy Review
This policy will be reviewed at least every two years to ensure compliance with evolving legal, regulatory, and governance standards.
Updates to this policy will be communicated across the Clean Investor Group and made accessible to all relevant stakeholders.