Whistleblowing Policy


The Great Barrier Reef Foundation (GBRF) is committed to the highest standards of conduct and ethical behaviour and full compliance with the law in all aspects of its business.

The aim of this Policy is to encourage the reporting of any instances of suspected or actual unethical, illegal, fraudulent or undesirable conduct involving the GBRF.

2           DEFINITIONS

In this policy:

Eligible Person means individuals who are, or have been, any of the following in relation to the GBRF:

(a)               an employee;

(b)               an officer;

(c)               a director;

(d)               an associate;

(e)               a contractor (any individual who supplies goods or services whether paid or unpaid);

(f)                an employee of a contractor;

(g)               a relative of a person referred to in any of paragraphs (a) to (f) above; or

(h)               a dependent of any individual referred to in any of the paragraphs (a) to (f) above, or of such individual's spouse.

Whistleblower means an Eligible Person who makes a disclosure in the manner set out in this Policy about Reportable Conduct.

3           SCOPE

This Policy applies to all Eligible Persons and applies to the GBRF's activities globally.

This Policy applies in conjunction with the GBRF's other policies and procedures.


It is the responsibility of all Eligible Persons to ensure that they understand and comply with this Policy.

If any individual is uncertain about any aspect of this Policy, or is uncertain as to the appropriate course of action to take in a situation relevant to this Policy, they should contact the GBRF's Head of Operations.

The Audit, Risk and Compliance Committee appointed by the GBRF Board is responsible for the overall administration of the Policy and will monitor its implementation by:

(a)               reviewing the suitability and effectiveness of the Policy at least every 2 years to ensure that it meets best practice standards and any legislative requirements;

(b)               reviewing and reporting on any reports made under this this Policy every 6 months; and

(c)               reviewing and reporting on any breaches of this Policy every 6 months.


The GBRF encourages individuals to report under this Policy if they believe that a GBRF's director, officer, employee, contractor, supplier or other person who has business dealings with the GBRF is engaging in conduct which:

(a)               amounts to misconduct or an improper state of affairs or circumstances in relation to the GBRF;

(b)               is dishonest, fraudulent or corrupt, including bribery or any other activity in breach of the GBRF's Anti-Bribery and Anti-Corruption Policy;

(c)               is an offence against or contravention of any State or Federal law;

(d)               represents a danger to the public or the financial system;

(e)               is unethical or in breach of the GBRF's policies (such as dishonestly altering company records or data, adopting questionable accounting practices or wilfully breaching the GBRF's Code of Conduct or other polices or procedures of the GBRF);

(f)                is potentially damaging to the GBRF or the GBRF's reputation, a member of the GBRF's Personnel or a third party;

(g)               amounts to an abuse of authority;

(h)               may cause financial loss to the GBRF or damage the GBRF's reputation or be otherwise detrimental to the GBRF's interests;

(i)                 involves harassment, discrimination, victimisation or bullying; or

(j)                 involves any other kind of serious impropriety.

(collectively, Reportable Conduct)


Where an Eligible Person has reasonable grounds to suspect the occurrence of Reportable Conduct, the GBRF encourages that person to make a disclosure in accordance with procedures set out in this section 6 below (a Disclosure).

6.1        Employees

Any employee of the GBRF may make a Disclosure to their immediate supervisor or manager.  

6.2        Any Eligible person

Any person may make a Disclosure to a director of the GBRF or any of the following individuals:

Director of Risk and Compliance

Damien Dennis

07 3171 0413
Chair of the Audit, Risk and Compliance Committee

Phillip Strachan

07 3252 7555
Managing Director Anna Marsden(collectively, the Authorised Recipients)


Where a Disclosure is made to an immediate supervisor or manager, that individual will notify an Authorised Recipient in a manner consistent with the confidentiality protections set out in 8.1 below.

The Authorised Recipient will investigate all actual, suspected or potential instances of Reportable Conduct as soon as possible after a Disclosure is made. Any investigation will be conducted in an objective and fair manner, and otherwise as is reasonable and appropriate having regard to the circumstances and the nature of the incident. The Authorised Recipient will notify the individual (unless that individual has remained anonymous) of the outcome of the investigation.

Authorised Recipients will report to the Audit, Risk and Compliance Committee on the number and type of Whistleblower Disclosures every six months. These reports will be made on a 'no names' basis to ensure compliance with the confidentiality protections set out in 8.1 below.


The GBRF is committed to ensuring Whistleblowers are protected from any form of retaliation as a direct consequence of making a Disclosure under this Policy. This includes, but is not limited to:

(a)               dismissal;

(b)               demotion;

(c)               harassment and bullying;

(d)               discrimination; or

(e)               disciplinary action.

8.1        Confidentiality

The GBRF encourages Whistleblowers to make a declaration regardless of whether they put their name to the Disclosure or not. However, concerns expressed anonymously are sometimes more difficult to investigate and the Authorised Recipient will not be able to notify the Whistleblower of the outcome of the investigation.

Disclosures made under this Policy will be treated confidentially and the GBRF will not, nor will any supervisor, manager or Authorised Recipient, reveal the identity of the Whistleblower unless:

(a)              the Whistleblower consents; or

(b)              the GBRF is required by law to disclose the Whistleblower's identity; or

(c)               we consider it appropriate to make a disclosure to a regulator under legislation.

8.2        Consequences of breaching this Policy

The Head of Operations will investigate all reported actual, suspected or potential breaches of the Policy as soon as possible after an incident has been reported. The investigation will be conducted in a fair manner and otherwise as reasonable and appropriate having regard to the nature of the incident and the circumstances.

Endorsed by Audit, Risk and Compliance Committee: 14 August 2018

Endorsed by Board: 23 August 2018