Draft Whistleblowers Policy

Item 13.4 - Attachment 1

Draft Whistleblowers Policy

1. POLICY – SUPPORT FOR PERSONS WHO MAKE DISCLOSURES

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.

2. PURPOSE OF THE POLICY

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.

3. OBJECTIVES OF THE PROTECTED DISCLOSURES ACT

The Protected Disclosures Act 1994 commenced operation on 1 March 1995. The purpose of the Act is to ensure that public officials who wish to make disclosures under the legislation receive protection from reprisals, and that the matters raised in the disclosures are properly investigated.

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. WHAT DISCLOSURES ARE PROTECTED BY THE ACT?

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.

5. MAKING A DISCLOSURE UNDER THIS POLICY

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	Mobile
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).

6. ROLES AND RESPONSIBILITIES

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;

7. ALTERNATIVE AVENUES FOR DISCLOSURES

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.

8. RIGHTS OF PERSONS THE SUBJECT OF DISCLOSURES

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).

9. PROTECTION AVAILABLE UNDER THE ACT COMMITMENT TO PROTECT WHISTLEBLOWERS

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.

11. NOTIFICATION OF ACTION TAKEN OR PROPOSED

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. DEFINITIONS

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. REVIEW OF THIS POLICY ADMINISTRATION

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, 6^th 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

	SECTION	PAGE
1.0	POLICY – SUPPORT FOR PERSONS WHO MAKE DISCLOSURES	1
2.0	PURPOSE OF THE POLICY	1
3.0	OBJECTIVES OF THE PROTECTED DISCLOSURES ACT	2
4.0	WHAT DISCLOSURES ARE PROTECTED UNDER THE ACT?	6
4.1	What disclosures are protected	6
4.2	What disclosures are not protected	6
5.0	MAKING A DISCLOSURE UNDER THIS POLICY	7
6.0	ROLES AND RESPONSIBILITIES	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	ALTERNATIVE AVENUES FOR DISCLOSURES	12
8.0	RIGHTS OF PERSONS THE SUBJECT OF DISCLOSURES	13
9.0	PROTECTION AVAILABLE UNDER THE ACT	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	NOTIFICATION OF ACTION TAKEN OR PROPOSED	16
12.0	DEFINITIONS	2
12.1	Disclosure
12.2	Corrupt Conduct	2
12.3	Maladministration	2
12.4	Serious and Substantial Waste	4
13.0	ADMINISTRATION	17
14.0	FLOW CHART OF INTERNAL REPORTING SYSTEM	18
~~15.0~~	~~INFORMATION SHEET~~	19