WHISTLEBLOWER POLICY

SEE SOMETHING, SAY SOMETHING, WE WANT TO HEAR FROM YOU

Scope of this policy

This policy extends to Flight Centre Travel Group Limited’s (FCTG) global business including board

members, employees, contractors, agents, representatives, licensees and franchisees (where relevant).

What is Whistleblowing?

FCTG is committed to developing a culture where all staff are encouraged to raise concerns about poor or unacceptable practices, misconduct or anything improper, and can do so safely. The purpose of this policy is to promote responsible disclosure about issues where the interests of others, including the public, or of FCTG itself, are at risk. Such issues might include:

  • Dishonesty
  • Fraud
  • Theft
  • Harassment
  • Workplace bullying
  • Discrimination (sex, age, gender, race, religion e)
  • Bribery and corruption
  • Modern Slavery
  • Manipulation or falsification of financial records
  • Illegal activities
  • Unethical behaviour
  • Unsafe work practice
  • Victimisation
  • Breach of Code of Conduct or other group policies
  • Other serious improper conduct, or
  • Any other conduct which may cause financial or non-financial loss to FCTG or be otherwise detrimental to the interests of the Organisation

Responsibilities for all board members, employees, contractors, agents, representatives, licensees and franchisees

Each board member, employee, contractor, agent, representative, licensee and franchisee is in a position of trust and must adhere to appropriate standards of ethical behavior including compliance with FCTG’s policies, applicable laws and regulations. Each board member, employee, contractor, agent, representative, licensee and franchisee is expected to make every effort to protect the interests of FCTG, including taking action to prevent the occurrence of inappropriate practices and/or behavior.

To the extent that a person becomes aware of inappropriate behavior, misconduct or anything improper, they should follow the procedures outlined below.

Confidentiality

Employees can raise their disclosure anonymously or ask that their identity not be disclosed. Anonymous disclosures will be investigated to the extent they can be without revealing your identity.

If you make an anonymous disclosure to PwC through FCGT’s whistleblower service you will be given a unique identifier number that you can quote in subsequent conversations with PwC. This will allow you to continue an ongoing dialogue with them as investigations progress.

FCTG encourages individuals to provide their name when they raise a concern, where possible. This will assist where additional information is required to further an investigation.

Commitment to protecting employees

FCTG is committed to protecting employees in making genuine disclosures and has appointed a whistleblower protection officer, Peter Feros, Group General Counsel, who has the responsibility of providing individual employees with protection against disadvantage.

Anonymity

All reasonable efforts will be made to ensure that anonymous disclosures remain anonymous. Anonymity cannot be guaranteed in certain circumstances (e.g., court orders).

Immunity from Disciplinary Action

Retaliation against a whistleblower will not be tolerated.

If an allegation is made in good faith, but is not confirmed by the investigation, no action will be taken against the person raising the misconduct concern.

FCGT will focus on the quality of the information that is reported, not the motivation of the whistleblower. However this is not a forum for allegations which are vexatious or frivolous. FCTG expects its people to use the whistleblower process appropriately and with honesty.

Reporting concerns

If you have any known or suspected concerns about poor or unacceptable practices, misconduct, anything improper or the appropriateness of someone’s conduct, you should make a disclosure about it. Your responsibility is to report this concern to:

If you feel uncomfortable or unable to report your concern to these people, please contact FCTG’s confidential and free whistleblower service that is operated 24/7 by an independent third party, PricewaterhouseCoopers (PwC) by either:

  • Calling one of the free-call numbers below:

AUS: 1800 308 064

Canada: 855 790 6901

China: 10 800 261 1332

Denmark: 802 53686

Dubai: 800 0610 4387

Germany: 0800 181 7541

HK: 800 903 702

India: 000 800 610 1115

Indonesia: 001 803 61 994

Ireland: 1800 222 386

Japan: 0034 800 401 244

Malaysia: 1800 818 537 

Mexico: 1800 123 9560

Netherlands: 0800 022 6792

New Zealand: 0800 854 249

Norway: 800 15501

RSA: 800 989 000

UK: 0800 015 9714

USA: 855 522 8911

Singapore: 800 6167 054

Sweden: 020 795 689

Thailand: 1800 011 811

Anywhere (non- freecall): +61 7 3257 8155, or

Unfortunately FCTG operates in some Countries where free-call services are unavailable. If there is no free-call number listed for the Country you reside in, please call the “Anywhere (non-freecall)” number and advice the PWC representative that you are calling to make a whistle blower disclosure from a Country with no free-call number access. If you provide your contact details the PWC representative will call you back to continue to take the details of your disclosure.

  • Email: flightcentre@au.pwc.com

PwC will take your call or read your email, consider your concern and undertake an appropriate course of action.

Any disclosures will be investigated fully. The person raising the matter will be kept informed of the progress and the outcome of the investigation, within the constraints of maintaining confidentiality or observing legal restrictions generally.

Group Reporting Procedures

The Board, through the Audit and Risk Committee, will receive confidential reports on the number and type of whistleblower incidents half yearly to enable it to address any issues at a regional or group level. These reports will be made on a “no name’s basis”, maintaining the confidentiality of matters raised under this policy.

Where the subject matter of a report could be materially price sensitive, the person receiving the complaint should consider whether any action needs to be taken under the company’s continuous disclosure policy (while maintaining confidentiality to the full extent required by law).

Review of policy

This policy and the actions outlined above will be reviewed to ensure they are relevant and appropriate for our workplace.

Related policies and procedures

  • Code of Conduct
  • Anti-Fraud policy
  • Anti-bribery and corruption policy
  • Equal Employment Opportunity policy
  • Occupational health and Safety policies
  • Finance policies
  • Communications, Email and Internet policy

Endorsement

FCTG’s board and executive team is committed to this policy and its implementation and to ensuring an enjoyable and healthy and safe working environment.