Whistleblower Protection  

July 2025 

This policy guides the organisation on obligations under the Aged Care Act 2024 and the Corporations Act 2001 to support workers, consumers/ Supporters and those involved in their care to raise concerns about breaches of the Aged Care Act and other legislation. 

Policy Overview 

The policy outlines the processes for reporting breaches and the organisation’s obligations for protecting whistleblowers. The procedures describe the measures required to safeguard and support any person who discloses information or raises concerns relating to actual or suspected breaches of the Aged Care Act 2024 or other legislation. These measures are essential for protecting consumers accessing funded aged care services and are intended to enable the identification and investigation of events before they become reportable incidents. 

Key Policy Points 

1. Governing Body Responsibilities: 

a. Ensure the Whistleblower Protection Policy is part of the organisation’s broader risk management and corporate governance framework. 

b. Ensure that the organisation addresses and mitigates the trends, themes, and emerging risks highlighted by the disclosures made under this policy as part of its risk management and corporate governance work plans. 

• Director Responsibilities: 

c. Ensure workers, consumers, their supporters, and others feel empowered to disclose wrongdoing without fear of repercussions. 

d. Ensure the Leadership Team, managers, and supervisors receive appropriate training on this policy, including how to manage disclosure reports and the protections required for whistleblowers. 

e. Ensure that information identifying or leading to the identification of a whistleblower remains confidential. 

f. Ensure that disclosures of wrongdoing are dealt with appropriately and promptly. 

g. Ensure that persons charged with responsibility for identifying, investigating, and managing circumstances resulting from disclosures of wrongdoing are appropriately qualified and trained. 

h. Ensure whistleblowers who make protected disclosures receive legal protections unless an exemption applies. 

2. Reasonable Grounds and False Reports: 

a. A person making a disclosure relating to wrongdoing must have reasonable grounds for making a report. An allegation with no supporting information is unlikely to be considered as having reasonable grounds. 

b. Individuals will not qualify for whistleblower protections if they knowingly disclose false or misleading information, and workers who knowingly report false information may be subject to disciplinary action. 

3. Who, What and Considerations: 

a. Disclosures can be made by a range of individuals, including workers, consumers and their supporters, third-party suppliers, or family members of workers. 

b. Disclosures may be received by individuals in various roles, such as a responsible person or an aged care worker of an aged care provider, as well as officials of the Aged Care Quality and Safety Commission or the Department of Health and Ageing, or ASIC. 

c. When making a disclosure, the individual must first inform the recipient that they wish to make a report as a whistleblower so the recipient can make appropriate arrangements to maintain confidentiality for the individual’s identity. 

d. Workers are encouraged to report disclosures to their supervisor, the Director or the Governing Body Chair. 

e. Consumers, their family members, carers, and supporters are encouraged to report disclosures by completing the details in the Feedback and Complaints Form and submitting it via the locked box at Reception or by post. 

4. Protection of Whistleblowers 

a. To qualify for protection as a whistleblower, individuals need to meet requirements for the job title of the person receiving the disclosure, the subject of the disclosure and the type of organisation the disclosure concerns. 

b. Whistleblowers are protected by law with measures including identity confidentiality, job security, and protection from retaliation. 

5. Investigation of Disclosures 

a. The organisation’s staff will respond promptly to all legal requests for information. Information requests from external parties will be handled in accordance with the Complaints and Feedback Policy and Procedures and the Privacy Policy and Procedures. 

b. The Whistleblower Investigation Officer (WIO) will lead the internal investigation process, including the response to external agencies. Any staff who are impacted will be offered support through the employee assistance program. 

c. The Leadership Team must take appropriate measures in accordance with the report’s findings, including notifying regulatory and/or enforcement agencies (if required) or undertakings required by an external organisation. 

d. The investigation’s findings and any actions taken will be reported to the whistleblower (while maintaining confidentiality) and relevant stakeholders. 

Further Information

Contact Belvedere Aged Care Privacy Officer via email: privacy@belvedere.com.au