Whistleblower Procedure

1. Purpose

To ensure all employees are aware of the whistleblower procedure and to promote responsible reporting of issues where the interests of stakeholders, including employees, customers or MTC, are at risk. Such issues might include but are not limited to:

• A criminal offence e.g. theft
• The breach of a legal obligation
• Fraud/financial embezzlement
• A danger to the health or safety of any individual
• Damage to MTC property or the environment
• Deliberate covering up of evidence leading to an offence or irregularity
• Undisclosed significant conflict of interest

This procedure is designed to:

• Encourage and facilitate disclosure of misconduct
• Provide anonymity for employees that makes these disclosures
• Provide protection for employees that may fear or suffer reprisals in relation to such disclosures
• Ensure that the matters disclosed are properly investigated and dealt with in a timely manner
• Ensure individuals who disclose wrongdoing can do so safely, securely and with confidence that they will be protected and supported
• Provide transparency around the process for receiving, handling and investigating disclosures.

2. Scope

This Standard Operating Procedure (SOP) applies to all reporting individuals—defined as any internal or external stakeholder associated with MTC FutureReady Ltd and MTC Recruitment Ltd. This includes, but is not limited to:

• Current and former employees
• Board and committee members
• External parties – e.g. Contractors, volunteers

3. Definitions

An eligible whistleblower is a person who makes a report to an eligible recipient in connection with reportable conduct.

4. Procedure

5.1 Reporting Channels

5.1.1 Employees of MTC and MTCRL

Employees should first report concerns to their manager or a member of the Executive Leadership Team (ELT). Where not appropriate, employees may report confidentially to: GM Governance, Risk and Compliance, GM People and Culture or CEO

Staff may email the centralised email [email protected]

Where the concern may involve either CEO, GM People & Culture or GM Governance Risk and Compliance, employees may escalate the report confidentially and directly to the MTC FutureReady Board Chair or the Chair of the Audit, Investment and Risk Committee.

All staff may also report confidentially and anonymously via STOPline, an independent and confidential whistleblower service through:

• Web: mtcaustralia.stoplinereport.com
• Phone: 1300 304 550
• Email: [email protected]
• Mail: PO Box 403, Diamond Creek VIC 3089

MTC STOPLine reports are accessible by the General Manager People & Culture and the GM Governance Risk and Compliance. The STOPLine service includes functionality to escalate disclosures involving the Board or CEO directly to the Chair of the Board and the Chair of the Audit, Investment and Risk Committee, ensuring appropriate oversight and confidential handling of sensitive matters.

5.1.2 External Stakeholders and Anonymous Reports

External stakeholders may also report concerns directly via STOPline as outlined above, or also via email [email protected]

5.2 Process

5.2.1 Phase 1 Initial Disclosures

Internal (employee) disclosure

Any employee who wishes to raise any whistleblower concerns should first speak or write to their immediate Manager or Executive Leadership Team Member. Employees may also report through the reporting channels mentioned in Section 5.1.1

The Manager to whom the concern was reported will note the key points of the concern and check that the employee has a copy of the Whistleblower Policy and this SOP. The Manager will also assure the employee of confidentiality, and appropriate consent is sought  and recorded prior to collecting or sharing information ensuring that disclosures are made voluntarily and only when the individual wishes to provide them.

The Manager will then refer the concern to the GM Governance Risk and Compliance, GM People & Culture or CEO and hand over any written materials. All information must be entered and managed within the Breach, Fraud and Incident Register within FOLIO.

External disclosures

All whistleblower concerns raised by external stakeholders can report directly via the channels in 5.1.2 – Concern raised via internal or external channels. The GM Governance Risk and Compliance, GM People & Culture or CEO will then enter the information and managed within the Breach, Fraud and Incident Register in FOLIO.

5.2.2 Phase 2: Investigation

The CEO, in conjunction with the GM Governance Risk and Compliance, will use all reasonable endeavours to decide what action to take and associated timeframes within 24 hours of reporting.

This may include initiating an internal investigation which will be conducted, under the principles of procedural fairness. The investigation will normally commence with the appointment of an investigating officer, who will normally be the GM Governance Risk and Compliance. The whistleblower (where identified) will be informed about the action to be taken.

The investigating officer may ask the whistleblower how they think the matter might best be resolved. If the person has any personal interest in the matter, it is essential that this is made known at the outset. For employees, the matter may be pursued through the P 011 Personal Grievance Policy where necessary.

If an investigation is undertaken, the investigating officer will keep the whistleblower (where identified) informed about what is happening, as far as possible. Where requested, reports can be made in writing. In some cases, it may not be possible to report, to protect privacy and confidentiality of the people involved.

All investigations undertaken will take evidence and risk-based approach, ensuring that all information made available during the process is taken into consideration as part of the decision-making process. Where necessary, the investigating officer may call upon subject matter experts (either internal or external) to provide input.

Investigation Reports developed, including the outcomes will ensure objectivity and procedural fairness. Individuals involved will always have the opportunity and right to reply to all allegations made.

5.2.3 Phase 3: Outcome and reporting

All outcomes must be communicated to the respective parties involved, maintaining privacy and confidentiality. All findings and outcomes will be provided within a final report, with individuals given the right to respond within 10 business days of report being drafted.

While MTC aims to complete all whistleblower investigations within 28 days of the initial report, it is acknowledged that the complexity and sensitivity of certain matters may require extended timeframes. Factors such as the availability of key individuals or the scope of the matter can impact the duration. In such cases, the investigating officer must document the reasons for the delay and provide regular progress updates to relevant stakeholders, including the whistleblower (where identified) the CEO, GM P&C and the Audit, Investment & Risk Committee (through the Chair) Timely communication and transparency remain paramount throughout the process.

5.3 Escalation and Board Communication

Escalation of whistleblower matters is required when whistleblower allegations involve:

• Any member of the Executive Leadership Team, Board Director or a Board Committee Member
• Matters that present significant material risks to the business, including (but not limited to) reputational damage, potential loss of funding

In such cases, the matter must be promptly reported to the Board Chair and/or the Chair of the Audit, Investment & Risk Committee.

The GM Governance, Risk and Compliance, in consultation with the CEO and GM People and Culture is responsible for ensuring that the matters are documented and undergo the same process, and is reported to the Audit, Investment and Risk Committee and the Board.

Critical incidents requiring urgent attention, immediate notification to the Board Chair and Chair of the Audit, Investment & Risk Committee is mandatory to ensure timely oversight and governance response.

5.3.1 Escalation Matrix