This Procedure is governed by the Australian Catholic University (ACU) Protected Disclosures Policy (Policy).
Specific terms defined in clause 2 of the Policy have the same meaning wherever they appear in this
This Procedure outlines the framework for supporting Reportable Conduct including:
how a Discloser can make a Protected Disclosure;
the process for dealing with Protected Disclosures; and
communication with the Discloser and Eligible Whistleblower during any process adopted in accordance with this
3. How to make a Protected Disclosure
3.1. ACU recommends that Disclosers follow this Procedure when making a Protected Disclosure.
3.2 A Discloser should contact any of the Eligible Recipients listed in clause 2 of the Policy either by:
directly contacting the Eligible Recipient;
telephoning or sending a facsimile to the confidential Protected Disclosure Hotline Service as set out in Item 2 of Appendix A; or
using one of the other confidential communication methods (email service, online report, drop box or postal service) as set out in Item 3 of Appendix
3.3 ACU recommends that the Discloser provides all written or other evidence in their possession to the Eligible Recipient at the time of making the Protected Disclosure or within a reasonable period. This will enable the matter to be efficiently dealt with. The eligible Recipient may ask the Discloser to provide further information or documents in relation to the Protected Disclosure at any time.
4. The University’s Process for Dealing with a Protected Disclosure
4.1 The way ACU will investigate a disclosure of improper conduct or state of affairs will depend on who raises the concern, the seriousness and nature of the conduct disclosed, and who receives the disclosure. The objective of an investigation is to determine whether there is evidence which substantiates the concern raised in the
4.2 The usual steps in responding to a disclosure are set out
4.3 If the disclosure is appropriately dealt with under this Procedure, ACU will endeavour to:
investigate the disclosure within a reasonable period of time;
ensure that any investigation is fair and objective;
avoid conflicts of interest in carrying out any investigation; and
keep information relating to Protected Disclosures (including the identity of the Discloser) confidential, except as required by law and permitted under the Policy and this
4.4 The investigation team will be coordinated by the Protected Disclosure Officer. In some cases, ACU may appoint external investigators such as lawyers or forensic
4.5 If the Discloser can be contacted, the Protected Disclosure Officer will discuss the likely steps of the investigation with the Discloser (including whether the Discloser consents to their identity being disclosed) and provide the discloser with updates from time to time (where appropriate).
4.6 The outcome of any investigation will be reported on a confidential basis to the Chair, Audit and Risk Committee, and where possible, to the Discloser. If the investigationsubstantiates the disclosure, ACU is committed to addressing any wrongdoing, to the extent practicable in the circumstances.
5. Updates to this Procedure
This Procedure will be reviewed frequently and updated as required.
Major or Minor Revision
Description of Revision(s)
15 June 2016
Procedure approved by Senate
30 November 2017
Initial review of the operation of the Procedure by Senate
4 December 2019
Major amendments consequent upon legislative changes to the Corporations Act 2001 (Cth) approved by Senate