Item 13.4 - Attachment 1 |
Draft Whistleblowers Policy |
CODE OF CONDUCT
Whistleblowers
Protection Policy
Adopted by Council
(Minute 7967)
Policy Number 228
DRAFT
Item 13.4 - Attachment 1 |
Draft Whistleblowers Policy |
INDEX
|
SECTION |
PAGE |
1.0 |
1 |
|
2.0 |
1 |
|
3.0 |
2 |
|
4.0 |
6 |
|
4.1 |
What
disclosures are protected |
6 |
4.2 |
What
disclosures are not protected |
6 |
5.0 |
7 |
|
6.0 |
8 |
|
6.1 |
Employees |
8 |
6.2 |
Group
Managers and Service Managers |
8 |
6.3 |
The
Investigating Officer |
9 |
6.4 |
Chief
Executive Officer |
10 |
6.5 |
The
Lord Mayor |
11 |
7.0 |
12 |
|
8.0 |
13 |
|
9.0 |
14 |
|
9.1 |
Protection
against reprisals |
14 |
9.2 |
Protection
against actions |
14 |
9.3 |
Confidentiality |
15 |
9.4 |
Freedom
of Information exemption |
15 |
10.0 |
16 |
|
12.0 |
2 |
|
12.1 |
Disclosure |
|
12.2 |
Corrupt
Conduct |
2 |
12.3 |
Maladministration |
2 |
12.4 |
Serious
and Substantial Waste |
4 |
13.0 |
17 |
|
14.0 |
18 |
|
|
|
19 |
Draft Whistleblowers Policy |
Parramatta City Council expects every employee and councillor to put the
interest of the community before their own personal interests therefore:-
Parramatta City Council does not tolerate corrupt conduct,
maladministration or serious and substantial waste of public money.
Parramatta City Council is committed to the aims and objectives
of the Protected Disclosures Act 1994. Council
recognises the value and importance of contributions of staff to enhance
administrative and management practices and strongly supports disclosures being
made by its staff or councillors which disclose corrupt conduct,
maladministration, or serious and substantial waste of public money.
The Chief
Executive Officer and Parramatta City Council are committed to protecting and
respecting any member of staff who makes a bona fide disclosure, not just those
who make disclosures covered by the Protected
Disclosures Act 1994.
The Chief Executive Officer will take all reasonable steps to provide protection to staff who
make such disclosures from any detrimental action in reprisal for the making of
the disclosure.
This Policy establishes an
internal reporting system for the reporting of disclosures of corrupt conduct,
maladministration or serious and substantial waste of public money by
Parramatta City Council’s staff and its councillors. The system enables such
internal disclosures to be made to Chief Executive Officer,any Group Manager, Unit Manager or Service Manager of
Parramatta City Council, or the Internal Auditor, or through a toll-free
telephone Hotline Service. Councillors may report matters to the Lord Mayor
or the Chief Executive Officer.
This policy is designed to
complement normal communication channels between supervisors and staff. Staff
are encouraged to continue to raise appropriate matters at any time with their
supervisors, but as an alternative have the option of making a protected
disclosures in accordance with this policy.
This policy is not intended to
replace legislation and is to be read in conjunction with Council’s Code of
Conduct, and relevant legislation, policies and procedures.
The Protected Disclosures Act 1994 commenced operation on
The Act aims to encourage
and facilitate the disclosure - in the public interest - of corrupt conduct,
maladministration and serious and substantial waste in the public sector. This
is achieved by:
· enhancing and augmenting
established procedures for making disclosures concerning such matters;
· protecting persons from
reprisals that might otherwise be inflicted on them because of these
disclosures; and
· providing
for those disclosures to be properly investigated and dealt with.
4.1 What disclosures are protected?
Disclosures are protected under The Act if they:
· are
made:
- in accordance with this Internal
Reporting Policy; or
- to the Chief Executive Officer; or
- to one of the investigating authorities
nominated in the Act; and
· show or
tend to show corrupt conduct, maladministration, or serious and substantial
waste of public money by the Parramatta City Council or any of its staff; and
· are made voluntarily.
4.2 What
disclosures are not protected?
A disclosure is not
protected under the Act if it is made by a public official in the exercise of a
duty imposed by or under any other Act.
Protection is also not available for
disclosures which:
· are made frivolously
or vexatiously;
· primarily
question the merits of government or council policy ( policy as adopted by
Council); or
· are made
solely or substantially with the motive of avoiding dismissal or other
disciplinary action.
It is an offence to
wilfully make a false or misleading statement when making a disclosure.
The persons or
positions to which internal disclosures can be made in accordance with this
policy are:
· The Disclosure Hotline Service
· The Chief Executive Officer, Group Managers, Unit Managers, Service Managers and the Internal Auditor.
· The Manager, Service Audit & Review
· The Lord
Mayor (if the disclosure concerns or involves the Chief Executive Officer or a
councillor).
Staff or councillors who wish to make a disclosure may make
a formal report of the matter to any of the above officers. Contact details for
a number of the above officers is provided below.:
Contact |
Office |
|
Disclosure Hotline Service |
1300 ****** |
|
Chief
Executive Officer |
9806 5055 |
|
Manager,
Service Audit & Review |
9806 5235 |
0438 678
475 |
Lord Mayor |
9806
5301 |
|
Where persons contemplating making a
disclosure are concerned about publicly approaching any of the above, or they
wish to discuss the issue, they can ring the relevant officer and request a
meeting in a discreet location away from the workplace.
Notes: · A
council officer who wishes to make a protected disclosure which involves a
councillor may do so to the Lord Mayor or the Chief Executive Officer, or an
investigating authority (ie. the ICAC, NSW Ombudsman or Director-General of
the DLG). · A
councillor who wishes to make a protected disclosure which involves another
councillor may do so to the Lord Mayor, the Chief Executive Officer, or an
investigating authority (ie. the ICAC, NSW Ombudsman, or Director-General of
the DLG). · If
the Lord Mayor wishes to make a protected disclosure he or she may do so to
the Chief Executive Officer or an investigating authority (ie. the ICAC, NSW
Ombudsman or Director-General of the DLG). |
This Internal
Reporting Policy places responsibilities upon people at all levels within Parramatta City Council.
6.1 Employees and Councillors
Employees and
councillors are encouraged to report known or suspected incidences of corrupt
conduct, maladministration or serious and substantial waste in accordance with
this Policy.
All employees and councillors of Parramatta City Council have an
important role to play in supporting those who have made legitimate
disclosures. They must abstain from any activity that is or could be perceived to
be victimisation or harassment of persons who make disclosures. Further, they
should protect/maintain the confidentiality of persons they know or suspect to
have made disclosures.
6.2 Group
Managers, Unit Managers, and Service Managers Disclosure Officers
Group Managers, Unit Managers, and Service
Managers Disclosure officers are responsible for receiving, forwarding and or
acting upon disclosures in accordance with the Policy. Disclosure Officers receiving disclosures will:
· Clearly explain to persons making
disclosures what will happen in relation to the information received,
· When requested, make arrangements to
ensure that disclosures can be made privately and discreetly (if necessary away
from the workplace);
· Instruct the person making the disclosure
to keep the reporting confidential.
· Reduce to writing and date any
disclosures received orally (and have the person making the disclosure sign the
document);
· Deal
with disclosures impartially,
· forward disclosures to the Chief Executive Officer or acting Chief
Executive Officer for assessment;
· Take all necessary and reasonable steps
to ensure that the identity of persons who make disclosures, and the persons
the subject of disclosures, are kept confidential; and
· Support persons who make disclosures and
protect them from victimisation, harassment or any other form of reprisal.
6.3 The Investigating Officer The Disclosures Co-ordinator
The person nominated by the
Chief Executive Officer to investigate the disclosure The Disclosures Co-ordinator has a pivotal position in
the internal reporting system and acts as a clearing house for disclosures. The
Investigating Officer Disclosures
Co-ordinator will:
· Consult with the Chief Executive Officer on all disclosures
received
· Be
responsible for carrying out or coordinating any internal investigation arising
out of a disclosure, subject to the direction of the Chief Executive Officer in
carrying out his/her functions;
· Report
to the Chief Executive Officer on the findings of any investigation and
recommended remedial action;
· Take all
necessary and reasonable steps to ensure that the identity of persons who make
disclosures, and persons the subject of the disclosure, are kept confidential,
(where this is practical and reasonable)
· Support
persons who make disclosures and actively protect them from victimisation,
harassment or any other form of reprisal, and
· Impartially assess each disclosure to determine
- Whether
the disclosure appears to be a protected disclosure within the meaning of the
Act;
- Whether
the disclosure concerns another agency and should therefore be referred to the
principal officer of that agency; and
- The
appropriate action to be taken in relation to the disclosure, for example:
· No
action/decline;
· The appropriate
person to take responsibility for dealing with the disclosure,
· Preliminary
or informal investigation;
· Formal investigation;
· Prosecution
or disciplinary action;
· Referral
to an investigating authority for investigation or other appropriate action, or
· Referral
to the police (if a criminal matter) or the ICAC (if the matter concerns
corrupt conduct).
· Report
actual or suspected corrupt conduct to the Chief Executive Officer in a timely
manner to enable that officer to comply with the ICAC Act
6.4 Chief Executive
Officer
Disclosures
may be made direct to the Chief
Executive Officer unless the disclosure involves the Chief Executive Officer.
The Chief Executive Officer will:
· impartially assess each disclosure to determine:
- whether the disclosure appears to be a
protected disclosure within the meaning of the Act
- whether the disclosure concerns another
agency and should therefore be referred to the principal officer of that agency
- the appropriate action to be taken in
relation to the disclosure, for example.
· No action/decline;
· The appropriate person
to take responsibility for dealing with the disclosure; preliminary or informal
investigation,
· Formal investigation;
prosecution or disciplinary action;
· Referral to an
investigating authority for investigation or other appropriate action; or
· Referral to the police
(if a criminal matter) or the ICAC (if the matter concerns corrupt conduct);
· receive reports
from any employee who has investigated any disclosure on the findings of any investigation
and any recommendations for remedial action, and determine what action should
be taken;
· take all necessary
and reasonable steps to ensure that the identity of persons who make
disclosures, and the persons the subject
of disclosures, are kept confidential;
· have primary
responsibility for protecting staff who make disclosures, or provide
information to any internal or external investigation of a disclosure, from
victimisation, harassment or any other form of reprisal;
· be responsible tor
implementing organisational reform identified as necessary following
investigation of a disclosure; and
· report criminal
offences to the Police and actual or suspected corrupt conduct to ICAC (under
s.11 of the ICAC Act).
6.5 The Lord Mayor
The Lord Mayor may receive internal disclosures from any member of staff
of the council or any councillor concerning the Chief Executive Officer or a
councillor. The Lord Mayor will:
· impartially
assess each disclosure made to him/her about the Chief Executive Officer or a councillor
to determine.
- whether the disclosure appears to be a
protected disclosure within the meaning of the Act;
Note: In making this assessment the Lord Mayor should
seek guidance from: Chief Executive Officer (in the case of a disclosure about
a councillor), an investigating authority (i.e. the lCAC, or NSW Ombudsman), or
the Department of Local Government.
- the appropriate course of action to be
taken in relation to the disclosure (in consultation with the Chief Executive
Officer, if appropriate), for example:
· no action/decline,
· the appropriate person to take responsibility for
dealing with the disclosure; preliminary or informal investigation;
· formal investigation;
· prosecution or
disciplinary action,
· referral to an investigating authority for investigation
or other appropriate action; or
· referral to the police (if a criminal matter) or the
lCAC (if the matter concerns corrupt conduct)
· refer
disclosures to the Chief Executive Officer for appropriate action if they
concern the council's administration, within the day to day responsibilities of
the Chief Executive Officer;
· take all necessary and
reasonable steps to ensure that the identity of persons who make disclosures,
and the persons the subject of disclosures, are kept confidential;
Alternative
avenues available to staff for making a protected disclosure under the Act (other
than by means of the internal
reporting system established under this Policy for the purpose of the Act), are
as follows:
· to the Chief
Executive Officer; or
· to one
of the investigating authorities under the Act (i.e. the ICAC, NSW Ombudsman or
Director-General of the DLG).
· to a journalist or Member of Parliament (where
certain important pre-conditions apply).
Disclosures made to a journalist or a
Member of Parliament will only be protected if certain conditions are met:
· the
person making the disclosure to a journalist or Member of Parliament must have
already made substantially the same disclosure through the internal reporting
system or to the Chief Executive Officer or an investigating authority in
accordance with the Act; and
· the person
making the disclosure must have reasonable grounds for believing that the
disclosure is substantially true and the disclosure must be substantially true;
and
· the
investigating authority, public authority or officer to whom the matter was
originally referred has:
- decided
not to investigate the matter; or
- decided to investigate the matter but
not completed the investigation within six months of the original disclosure,
or
- investigated
the matter but not recommended any action in respect of the matter; or
- failed
to notify the person making the disclosure, within six months of the
disclosure, of whether the matter is to be investigated.
The rights of persons the subject of disclosures will also be protected.
In this regard:
· the confidentiality of
the identity of persons the subject of disclosures will be protected and maintained
(where this is practical and reasonable);
· disclosures will be
assessed and acted on impartially, fairly and reasonably;
· responsible officers
who receive disclosures in accordance with this Policy are obliged to:
- protect
and maintain the confidentiality of the identity of persons the subject of the
disclosures (where practical and reasonable);
- assess disclosures impartially: and
- act fairly to persons the subject of disclosures;
· all disclosures
will be investigated as discreetly as possible, with a strong emphasis on
maintaining confidentiality both as to the identity of whistleblowers and the
person the subject of disclosure (where practical and reasonable).
· where
investigations or other enquires do not substantiate disclosures, the fact the
investigation/enquiry has been carried out where practical`, the results of the
investigation/enquiry, and the identity of persons the subject of the
disclosures will be kept confidential, unless the persons the subject of the
disclosures request otherwise;
· the
person who is the subject of disclosures (whether protected disclosures under
the Act or otherwise) which are investigated by or on behalf of council, has the
right to:
- be informed as to the substance of the allegations;
- be informed as to the substance of any adverse
comment that may be included in a report/memorandum/letter or the like arising
out of any such investigation; and
- be given a reasonable opportunity to
put their case (either orally or in writing) to the persons carrying out the
investigation for or on behalf of council,
before
any final decision/determination/report/memorandum/letter or the like is made;
· where
the allegations in a disclosure have been investigated by or on behalf of council,
and the person the subject of the allegations is aware of the substance of the
allegations, the substance of any adverse comment, or the fact of the
investigation, he or she shall be formally advised as to the outcome of the
investigation, regardless of the outcome; and
· where
the allegations contained in a disclosure are clearly wrong or unsubstantiated,
the person the subject of the disclosure is entitled to the support of the
authority and its senior management (the nature of the support that would be
reasonable and appropriate would depend on the circumstances of the case, but
could include a public statement of support or a letter setting out the
authority's views that the allegations were either clearly wrong or
unsubstantiated).
All staff who report wrongdoing will be
supported, protected and their disclosures appropriately acted upon. No staff
member who reports wrongdoing through appropriate channels will suffer action
for having done so.
9.1 Protection against reprisals
The Act provides protection
by imposing penalties on a person who takes detrimental
action against another person substantially in reprisal for a protected
disclosure. Penalties can be imposed by means of fines and imprisonment. 'Detrimental action’ means action
causing, comprising or involving any of the following:
· injury, damage or loss;
· intimidation
or harassment;
· discrimination,
disadvantage or adverse treatment in relation to employment;
· dismissal
from, or prejudice in, employment; or
· disciplinary
proceeding.
In any such
proceedings the whistleblower only needs to show that he or she made a
protected disclosure and suffered detrimental action. It is then the
responsibility of the defendant to prove that the detrimental action shown to
have been taken against the whistleblower was not substantially in reprisal for
the person making the protected disclosure.
Any member of
staff or councillor who believes that 'detrimental
action is being taken against them substantially in reprisal for the making
of an internal disclosure in accordance with this Policy should immediately
bring the allegations to the attention of the Chief Executive Officer or Lord Mayor.
If the person who
made an internal disclosure feels
that such reprisals are not being effectively dealt with, they should contact
the ICAC, the NSW Ombudsman or the Director-General of the DLG.
If an external
disclosure was made to an investigating authority, that body will either deal
with the allegation or provide advice and guidance to the person concerned.
9.2 Protection against actions
The Act provides that a
person is not subject to any liability for making a protected disclosure and no
action, claim or demand may be taken or made of or against the person for making
the disclosure. This provision has effect despite any duty of secrecy or
confidentiality or any other restriction on disclosure by a public official.
A person who has made a protected disclosure has a defence of
absolute privilege in proceedings for defamation.
A person who has made a
protected disclosure is taken not to have committed any offence against an Act
which imposes a duty to maintain confidentiality with respect to any
information disclosed.
9.3 Confidentiality
The Act requires investigating
authorities, councils and council officers to whom protected disclosures are
made or referred, not to disclose information that might identify or tend to
identify the person who made the disclosures. The exceptions to the
confidential requirement are where:
· the
person making the disclosure consents in writing to the disclosure of that
information; or
· it is
essential, having regard to the principles of natural justice that the
identifying information be disclosed to a person whom the information provided
by the disclosure may concern; or
· the
investigating authority, public authority, officer or public official is of the
opinion that disclosure of the identifying information is necessary to
investigate the matter effectively; or disclosure is otherwise in the public
interest.
Decisions about
natural justice, effective investigation and public interest will be made by
the Chief Executive Officer. In all cases the person who made the disclosure
will be consulted before such a decision is made. Care must be exercised when
the person under investigation is to be questioned or given some information
about the investigation. It is important to ensure evidence cannot be “created
“ that is false or misleading or destroyed.
Note: If
guidance is needed in relation to the requirements of natural justice,
effective investigation and public interest, this may be sought from an
investigating authority.
9.4 Freedom of Information exemption
Under the Freedom of
Information Act 1989, a document is
exempt from release if it contains matter the disclosure of which would
disclose matters relating to a protected disclosure within the meaning of the
Act.
A person who makes a protected
disclosure must be notified, within six months of the disclosure being made, of
the action taken or proposed to be taken in respect of the disclosure.
If a disclosure is made
in accordance with this Policy, the Disclosure Co-ordinator is responsible for
the six month notification to the person who made the disclosure, unless this
responsibility has been retained by or allocated to another officer by the Chief
Executive Officer.
If a disclosure is made
to the Lord Mayor under this Policy, the Lord Mayor is responsible for such
notification to the person who made the disclosure, unless he or she directs
the Chief Executive Officer, or another nominated officer to assume this
responsibility.
The notification
provided to the person who made the disclosure should contain sufficient information
to demonstrate that adequate and appropriate action was taken, or is proposed
to be taken, in respect of the disclosure. This
should include a statement of the reasons for the decision made on or action
taken in response to the disclosure.
The notification should include
sufficient information to enable the person who made the disclosure to make an
assessment as to whether the circumstances listed in section 19(3)(a)-(c) of the Act (relating to
disclosures to members of Parliament and journalists) apply, i.e.
whether:
· a decision was made not to investigate
the matter; or
· a
decision was made to investigate the matter, but the investigation was not
completed within six months of the original decision being made; or
· a
decision was made to investigate the matter, but the investigation has not been
completed within six months of the original decision being made; or
· the
matter was investigated but no recommendation was made for the taking of any
action in respect of the matter.
Without such information it would be
difficult for the person to be able to properly assess whether it is
appropriate or warranted to make a disclosure to a Member of Parliament or
journalist.
11.1 Disclosure
A disclosure is a report, either written or verbal,
made in accordance with this policy. Three key concepts in the internal
reporting system are corrupt
conduct, maladministration and 'serious
and substantial waste of public
money' Definitions of these concepts are outlined below.
11.2 Corrupt
conduct
'Corrupt conduct' is defined
in the Independent Commission Against
Corruption Act (s.8 and 9). The definition used in the Act is intentionally
quite broad - corrupt conduct is defined to include the dishonest or partial
exercise of official functions by a public official. Conduct of a person who is
not a public official, when it adversely affects the impartial or honest
exercise of official functions by a public official, also comes within the
definition.
Corrupt conduct can take many forms, i.e. taking or offering bribes,
public officials dishonestly using influence, blackmail, fraud, election
bribery and illegal gambling are some examples.
11.3 Maladministration
‘Maladministration’ is
defined in the Protected Disclosures Act as
conduct that involves action or inaction of a serious nature that is:
The conduct covered by these terms includes:
· contrary to law, or
· unreasonable, unjust, oppressive or improperly discriminatory, or
· based wholly or partly on improper motives.
The
conduct covered by these terms includes:
contrary
to law, for example: |
|
|
· decisions or actions contrary to law · decisions or actions ultra vires ( i.e. the decision-maker had no power to make the
decision or to do the act) · decisions or actions contrary to lawful and
reasonable orders from persons or body’s with authority to make or give such
orders · breach of natural justice/procedural fairness · improper exercise of a delegated power (e.g.
decisions or actions not authorised by delegation or acting under the
direction of another) · unauthorised disclosure of confidential information · decisions or actions induced by fraud |
unreasonable,
for example: |
|
|
· decisions or actions inconsistent with adopted
guidelines or policy, inconsistent with other decisions or actions which
involve similar facts or circumstances not justified by any evidence, or so
unreasonable that no reasonable person could so decide or act (i.e.
irrational) · arbitrary, partial. Unfair or inequitable decisions
or actions · policy applied inflexibly without regard to the
merits of individual cases · relevant considerations not adequately taken into
account or irrelevant · considerations taken into account · serious delay in making decisions or taking action · failure to give notice of rights · giving wrong. Inaccurate or misleading advice leading
to detriment · failure to apply the law · failure to rectify identified mistakes, errors,
oversights or improprieties · decisions or actions based on incorrect or
misinterpreted information · failure to properly investigate |
unjust, for example: |
|
|
· decisions or actions not justified by any evidence,
so unreasonable that no reasonable person could so decide or act · partial, unfair, inequitable or unconscionable
decisions or actions |
oppressive, for example: |
|
|
· unconscionable decisions or actions · means used not reasonably proportional to ends to
be achieved · abuse of power, intimidation or harassment |
improperly
discriminatory, for example |
|
|
· inconsistent application of laws policies or
practices when there is no reasonable, justifiable or appropriate reason to
do so. · distinctions applied not authorised by law, or
failure to make a distinction which is authorised and/or required by law |
based
wholly or partly improper motive., for example. |
|
|
· decisions
or actions for a purpose other than that for which the power was conferred
(i.e in order to achieve a particular outcome) · conflicts
of interest · dishonesty
or decisions or actions in bad faith · seeking
or accepting gifts or benefits in connection with performance of official
duties · misuse
of public property, official services or facilities |
11.4 Serious and substantial waste
The term ‘serious and substantial waste’ – is not defined in the Protected Disclosures Act. The Auditor-General provides the following
working definition:
Serious and substantial waste refers to the
uneconomical, inefficient or ineffective use of resources, authorised or
unauthorised, which results in a loss/wastage of public funds/resources In addressing any complaint of serious and
substantial waste regard will be had, to the nature and materiality of the
waste The following delineation of the definition of
serious and substantial waste may be of assistance to public officials and/or
public authorities. Type: Absolute Serious and
substantial waste might be regarded in absolute terms where the waste is
regarded as significant, (for example $10,000 for Parramatta City Council
would be significant). Systemic The waste indicates a pattern which results from a
system weakness within public authorities. Material The serious and
substantial waste is/was material in terms of the public authority’s
expenditure or a particular item of expenditure or is/was material to such an
extent so as to effect a public authority’s capacity to perform its primary
functions. Material By Nature Not Amount The serious and substantial waste may not be
material in financial terms but may be significant by nature. That is it may
be improper or inappropriate [alternatively, this type of waste may
constitute ‘maladministration as defined in the Protected Disclosures Act |
Waste
can take many forms, for
example:
· Misappropriation
or misuse of public property,
· The
purchase of unnecessary or inadequate goods and services;
· Too many
personnel being employed in a particular
area, incurring costs which might otherwise have been avoided;
· Personnel
being remunerated for skills that they do not have, but are required to have
under the terms or conditions of their employment;
· Programs
not achieving their objectives and therefore the costs being clearly
ineffective and inefficient.
Waste can result from
such things as:
· The
absence of appropriate safeguards to prevent the theft or misuse of public
property;
· Purchasing
procedures and practices which fail to ensure that goods and services are
necessary and adequate for their intended purpose, and
· Purchasing
practices where the lowest price is not obtained for comparable goods or
services.
11.5 Detrimental
Action
'Detrimental action’ means action causing, comprising or involving any of the following:
· injury, damage or loss;
· intimidation
or harassment;
· discrimination,
disadvantage or adverse treatment in relation to employment;
· dismissal
from, or prejudice in, employment; or
· disciplinary
proceeding.
12.1 Authority
This policy
was approved by Resolution of Council on Minute
12.2 Review
This policy and
associated procedure have been reviewed and is consistent with the NSW
Ombudsman publication “Protected Disclosure Guidelines, 6th Edition” (April 2009). This Policy shall be reviewed
annually to ensure that it meets the object of the legislation and facilitates
the making of disclosures under the Act.
12.3 Owner
Service
Audit & Review have responsibility for review of this Policy.
12.4 Procedures
Procedures
to support this policy are filed in TRIM as D Procedures for Protected Disclosures