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 Navex Global through FCTG’s whistleblower service you will be given a report key and unique password that you can use to manage your report online or quote in subsequent conversations with Navex Global. 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.

FCTG 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:

  • your team leader or manager; or
  • their leader or someone in your reporting line such as area manager, nation leader, general manager, CFO, MD or X-team member;
  • Human resources or peopleworks;
  • Enterprise Risk:
  • Brett Anderson +61 407 392 084, brett_anderson@flightcentre.com
  • Matthew Griffin +61 430 244 580, matthew_griffin@flightcentre.com
  • Sonya Ryan +61 401 060 012, sonya_ryan@flightcentre.com;
  • Legal services;
  • Company Secretary, David Smith +61 404 856 317, david_smith@flightcentre.com;
  • Chairman of the Audit Committee: Rob Baker, rbak3698@gmail.com.

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, Navex Global by accessing our secure portal from any device:

Fctg.ethicspoint.com

Here you can report your concern online or look up numbers to report your concern by phone.  You can also manage reports made from this portal.

Navex Global will take your call or read your online report, 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 quarterly 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.