Whistleblower Policy

At Mayflower, we take pride in maintaining a culture of transparency and accountability. Our Whistleblower Policy provides a safe and confidential channel for employees, volunteers, and stakeholders to report any concerns or wrongdoing they may come across. We believe that by encouraging open communication, we can ensure the highest standards of integrity and ethics within our organisation.

Mayflower’s Board and Management encourages the reporting of all wrongdoing and will ensure that Whistleblowers are protected and supported.The intent of this policy is to outline:

• Mayflower’s commitment to enabling people to report, in good faith, any wrongdoing without fear of reprisal
• How Mayflower will deal with a whistleblowing report, and
• Set out the avenues available to a party to report an issue or wrongdoing to Mayflower.

This policy is not intended to prevent, or replace, normal communication channels between managers, workers, service providers, volunteers and residents to address questions, concerns, suggestions or complaints and personal work-related grievances. If any clarification is required in this regard, a party should speak with the Protected Disclosure Officer.

Mayflower will comply with its obligations to protect whistleblowers who, on reasonable grounds, report misconduct, any improper state of affairs or circumstances, or breach of law by, or about, Mayflower or an officer or employee of Mayflower.

This will include:

• Keeping a whistleblower’s identity confidential, if they request (however this may impact Mayflower’s ability to appropriately investigate the report), and
• Preventing harm or detriment to a whistleblower by a Mayflower officer or employee.

Disclosures may be made by employees, residents, family members, suppliers or by members of the public. A report should describe the circumstances of the situation and provide as much information as possible (including where appropriate providing supporting evidence) in relation to the matter.Disclosure can be made to a Mayflower Protected Disclosure Officer:

• Mayflower Board Director
• Chief Executive Officer
• Executive Director, Corporate Services
• Executive Director, Aged Care and Seniors Living
• Executive Officer, Aged Care, or
• Manager Seniors Living and Home Care

OR

Disclosure can also be made to externally to ASIC:

Australian Securities and Investment CommissionGPO Box 9827, Brisbane QLD 4001

asic.gov.au

Mayflower has a legal obligation to guarantee Whistleblowers identity protection (including confidentiality) and protection from detrimental acts or omissions (including dismissal from employment, disadvantage at work or reputational damage). If Mayflower breaches these protections, it will be liable under the Act and the Whistleblower will be entitled to seek compensation and other remedies such as protections from civil, criminal and administrative liability.

Mayflower will ensure that any employees mentioned in a Whistleblower Report will be afforded fair treatment and will be advised about the matter before any actions are taken to afford them natural justice and procedural fairness.

A Whistleblower must have reasonable grounds to suspect that a wrongdoing should be reported. The Whistleblower still qualifies for protection under the Act even if their disclosure turns out to be incorrect.Mayflower discourages deliberately false reporting to ensure the integrity of this Policy and the Act is maintained.A personal work-related grievance of itself is not a protected disclosure, if not a protected disclosure, the person raising such a grievance will be encouraged to do so under the provisions of the Grievance Resolution Policy.