Policies
At White Box, we’re committed to transparency, accountability and protecting the privacy of the people we work with. You can access our key governance documents and policies below.
White Box Enterprises considers the protection of privacy to be vital. We endeavour to consistently maintain the security of our website for all visitors and users. This policy outlines how White Box Enterprises collects and uses personal information.
Other websites may be accessible from our website via hyperlinks. Our privacy policy does not cover or reflect on the procedures of these other websites. It is the responsibility of the visitor/user to evaluate the privacy policy of other websites you choose to visit.
Collected Information
To help improve the service we provide through our website, certain information is collected from your browser to this website. This information is collected as statistical information and includes: IP address; browser type; language; and access times. This website also uses cookies (explained in next section) to track pages visited and information accessed within our website. This information is for statistical reference and site analysis only.
What is a cookie?
A cookie is a small data file that may write to your hard disk when visiting a site. The cookie primarily contains a USER ID that aids in tracking. Cookies can also retain information that you supply to the website. This information assists in maintaining the continuity of your browsing session and access to full use of the website.
Cookies cannot read data from your hard disk or from other cookie files. They can be disabled via your browser, however this may limit your access to all functionalities of a website.
Personal Information
Some functionalities of the website will ask for the voluntary supply of personal information. This information includes:
- name and email address for the purpose of subscribing to our e-newsletter; and
- name, email address, contact details and message for the purpose of assisting you with an enquiry to White Box Enterprises.
Access to and Right to Rectification of Personal Information
To access, update or remove information White Box Enterprises holds about you, contact White Box Enterprises directly via phone, email or enquiry form. We wish to ensure information held by White Box Enterprises is accurate and up-to-date.
Direct Marketing
White Box Enterprises does not collect information for direct marketing purposes, except where you have given permission by subscribing to our e-newsletter. This information is not sold to other parties and is for the express purpose of our own communication with you. At any time, you can opt out by clicking unsubscribe on the e-newsletter or communication that you receive.
Exceptions
Other than the above stated, White Box Enterprises will not attempt to identify users or their browsing activities except:
- in the event of an investigation by law enforcement: or
- where we believe we are required to collect and produce documentation relevant to fulfil obligations to third parties; including statutory organisations under local law.
Information Disclosure
In the course of providing services you request, personal information may be shared: with authorities; third parties engaged by White Box Enterprises to provide services to you; to protect intellectual property rights; or to enforce the Terms and Conditions of the website.
Security
The White Box Enterprises website uses the WordPress CMS to deliver, store and maintain our website and content. White Box Enterprises puts in place all reasonable measures to protect personal information from loss, prohibited access, misuse, alteration, destruction or unauthorised disclosure.
It’s safe to speak up
For White Box Enterprises, an ideal working environment is one where our values are lived and purpose is achieved. It’s not just an obligation, but also a desire to provide protection for those who might see practices that work against our ideal so that people feel safe to speak up, especially when it could feel like a hard thing to do.
1. About this Policy
This policy outlines the following important information to make sure that all eligible Whistleblowers have relevant information about what it is, understand the process that White Box Enterprises undertakes to resolve Whistleblowing disclosures, and how they will be protected in making a disclosure.
2. To whom, and how this Policy applies
This Policy applies ‘Workers’ in this Policy as a person who carries out work in any capacity for White Box Enterprises, including employees, contractors (and their employees), Officers, suppliers, and volunteers.
Those who can make a Whistleblowing disclosure are current or former employees, Officers, contractors, associates, as well as the spouses, relatives or dependents of any of these roles.
A Whistleblower is someone who makes an eligible disclosure of an activity within White Box Enterprises.
This Policy can be applied at any time and not just when laws are broken, meaning that it can be related where a Worker has acted in a way that constitutes serious wrongdoing, including unethical, illegal or corrupt conduct. However, it isn’t the only Policy that exists to resolve workplace issues and isn’t intended to replace other relevant policies that exist at White Box Enterprises (e.g. our Code of Conduct or Grievance Resolution Policy).
Where laws require us to comply with something or covers something not part of this Policy, they will always take precedence.
3. What is a disclosable matter?
Whistleblowing protections apply where the matter is defined as a disclosable matter (‘disclosure’) and is reported in line with what is otlined in this Policy. A disclosable matter is information that:
- is dishonest, negligent, fraudulent or corrupt;
- is illegal, such as theft, drug sale or use, violence, harassment, criminal damage to property or other breaches of state or federal legislation;
- is unethical, such as dishonestly altering company records or engaging in questionable accounting practices, or wilfully breaching White Box Enterprises’ Code of Conduct or other ethical statements;
- is potentially damaging or dangerous such as unsafe work practices or substantial wasting of resources;
- may cause financial loss to White Box Enterprises or damage its reputation, or be otherwise detrimental to White Box Enterprises’ interests; or
- involves any other kind of serious impropriety
A disclosure does not qualify for protection under Whistleblower protections where the information disclosed:
Whistleblowing Policy
- Refers to a personal work related grievance of the eligible Whistleblower, such as something relating to an individual’s employment, an interpersonal conflict, or a decision relating to terms and conditions of employment, or disciplinary activity;
- Does not have significant implications for White Box Enterprises; or
- A disclosure is not made in good faith, or is false (see section 6.1).
4. Making a Disclosure
4.1 Required information
It is important to provide as much information as possible so that the grounds for a disclosure can be evaluated. This includes any known details about the events underlying the report such as the:
- date;
- time;
- location;
- name of person(s) involved;
- possible witnesses to the events; and
- evidence of the events (e.g. documents, emails).
It is strongly suggested that reports are factually accurate, complete, from first-hand knowledge, presented in an unbiased fashion, and factually complete.
When making a disclosure, it’s handy to include any steps that may have already been taken to report the matter elsewhere or to resolve the concern.
4.2 How to make a report
At a minimum, a disclosure can be submitted to a Manager. In this instance, they must report the disclosure to the CEO, who is responsible for ensuring the matter is properly dealt with. This might include appointing an investigator to inquire into the allegations.
Where a Whistleblower wishes to disclose confidentially or hasn’t been able to resolve through direct management, disclosures may be reported directly to the CEO.
In the case of alleged or suspected wrongdoing involving senior management at White Box Enterprises, then the disclosure may be made to the Whistleblowing Officer, who is the Chairperson of the White Box Enterprises Board – contactable by email at [email protected].
White Box Enterprises will also protect individuals who have made a relevant disclosure to a legal practitioner or external regulators such as (but not limited to) the Australian Securities and Investments Commission (ASIC) and the Australian Prudential Regulation Authority (APRA).
Public Interest or Emergency disclosures have more strict criteria to qualify for Whistleblowing protections, and potential Whistleblowers can seek external advice where this may be the most appropriate avenue to make a Whistleblowing disclosure.
Whilst it’s encouraged that the person making the disclosure can be identified, anonymity through use of a pseudonym can be used. The Whistleblower would need to be contactable for any disclosure to be investigated.
5. Handling and investigating a disclosure
Within 14 days of receiving the disclosure, White Box Enterprises will aim to assess whether it qualifies for protection and to determine the investigation plan required to resolve the matter.
All reports of wrongdoing will be thoroughly investigated. The investigation will be conducted in a fair and impartial way and following the principles of natural justice; this means the investigation will be conducted without bias and that any person against whom an allegation is made will be given the opportunity to respond.
At the end of the investigation, the investigator will report their findings to the CEO (or appropriate reporting party), who will determine the appropriate response. White Box Enterprises is committed to implementing the findings and recommendations of any investigation to rectify any wrongdoing as far as practicable in the circumstances.
5.1 Communication with a Whistleblower
White Box Enterprises will endeavour to provide the person making the disclosure with regular updates throughout the investigation.
Once the investigation is completed, a verbal report will be made to the Whistleblower. This report will explain the findings and actions taken to the fullest extent possible within commercial, legal and confidentiality constraints. Where the Whistleblower chooses to remain anonymous, alternative arrangements may be made for providing a verbal report of the outcome of the investigation to that person.
5.2 Confidentiality
White Box Enterprises is committed to ensuring the confidentiality of eligible Whistleblowers.
White Box Enterprises may ask a Whistleblower’s consent to disclose their identity, or information that may potentially identify them. This would be done in situations where the disclosure could be appropriately investigated and resolved.
If a Whistleblower doesn’t consent, it is still lawful for White Box Enterprises to disclose their identity where:
- the disclosure is made to ASIC, APRA or the Australian Federal Police (AFP);
- the disclosure is made to a Legal Practitioner for the purpose of obtaining advice;
- the disclosure is authorised under the Corporations Act 2001 (Cth);
- it is reasonably necessary for the purpose of investigating the disclosure;
- disclosure is necessary to prevent or lessen a threat to a person’s health, safety or welfare
White Box Enterprises can take measures to protect their identity such as by redacting personal information, storing information and disclosures securely, referring to them in a gender-neutral context and only allowing qualified people to investigate the disclosure. However, it needs to be noted that the fact and the substance of a report may identify a Whistleblower to the person who is the subject of the disclosure (see section 6 for information on Protections).
The unauthorised disclosure of information relating to a report, the identity of the Whistleblower, or information from which the identity of the reporting person could be inferred will be regarded seriously and may result in disciplinary action, which may include summary dismissal.
All Whistleblowers must maintain the confidentiality of all such reports, and not disclose the information to any person unless legally warranted.
5.3 Respondent Management
White Box Enterprises will take reasonable steps to treat the person who is the subject of a disclosure fairly. The investigator will ensure that the person who is the subject of any disclosure that is investigated:
- is informed as to the substance of the allegations,
- is given the opportunity to answer the allegations before any investigation is finalised,
- is informed about the substance of any adverse comments that may be included in any report arising from the investigation before it is finalised, and
- has their defense set out fairly in any report.
Where the allegations in a report have been investigated, and the person who is the subject of the report is aware of the allegations or the fact of the investigation, the investigator must formally advise them of the investigation outcome. Relevant disciplinary procedures may apply depending on the outcome.
6. Whistleblower Protection
Irrespective of the outcome, Whistleblowers that report matters in good faith and have not been involved in the conduct reported will not be penalised or personally disadvantaged because they have reported a matter.
White Box Enterprises will not tolerate any detriment to a Whistleblower where any of the following is done as a result of them making a disclosure:
- retaliation, dismissal, suspension, demotion, or termination of their role;
- bullying, harassment, threats or intimidation;
- discrimination, subject to current or future bias, or derogatory treatment;
- harm or injury;
- damage or threats to their property, business, financial position or reputation; or
- revealing a Whistleblower’s identity without consent or contrary to law; or
- threatening to carry out any of the above actions.
A Whistleblower who believes they or their family have been the victim of any of the above because of their status as a Whistleblower, should immediately report the issue to the CEO or Whistleblowing Officer.
Any Worker who is found to have caused detriment to a Whistleblower because of a disclosure, may be subject to disciplinary measures including dismissal, or have their engagement ceased.
A Whistleblower, who has been involved in the reported conduct, may still be provided with immunity from White Box Enterprises initiated disciplinary proceedings by agreement with the CEO or Whistleblowing Officer. White Box Enterprises has no power to provide immunity from criminal prosecution.
6.1 False Disclosures
Where it is established by the investigator that the Whistleblower is not acting in good faith, or they have made a false or vexatious disclosure, no protections will apply and they will be subject to disciplinary proceedings, up to and including dismissal.
6.2 Support
Support throughout stressful periods like these can be provided as best as possible and this will be discussed with anyone who is part of a Whistleblowing disclosure. White Box Enterprises’ Employee Assistance Program (EAP) services will be available to all Whistleblowers and other Workers affected by the disclosure, should they require that support.