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, contractors and consultants, agents, representatives, licensees, franchisees, workers, casual workers and agency workers and current and former employees, officers and suppliers (where relevant) and is subject to the local policies and applicable law as it applies to the local FCTG entity.

What is Whistleblowing?

FCTG is committed to developing a culture where all people covered by this Policy are encouraged to raise concerns about suspected or actual misconduct or an improper state of affairs or circumstances relating to FCTG and its related bodies corporate, or its officers or employees (potential wrongdoing) and can do so safely.

The purpose of this Policy is to promote responsible disclosure about potential wrongdoing, particularly where the interests of others, including the public, or of FCTG itself, are at risk. Except to the extent where a local policy or applicable law applies to the local FCTG entity, 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

Potential Wrongdoing does not generally include personal work-related grievances. Personal work-related grievances are grievances relating to your employment that have implications for you personally (such as a disagreement between you and another employee or a decision about your promotion). Generally, these grievances should be raised via your team leader or your HR contact to allow those issues to be resolved most effectively. In some cases, these grievances may qualify for legal protection depending on the local policies and applicable law. For example, in Australia Attachment 1 sets out the additional protections provided by Australian law and the types of wrongdoing that can be reported and will (or will not) be protected by Australian law.

Responsibilities for all those covered by this Policy

The Board will not tolerate anyone being discouraged from speaking up under this Policy or being subject to detriment because they want to speak or they have done so. Disciplinary action, up to and including termination of employment or engagement, will be taken in respect of anyone shown to have caused detriment to a person in connection with speaking up under this Policy.

Each person covered by this Policy is in a position of trust and must encourage reporting under this Policy and adhere to appropriate standards of ethical behaviour including compliance with FCTG’s policies, applicable laws and regulations including without limitation, local policies and applicable laws. Each person covered by this Policy is expected to make every effort to protect the interests of FCTG, including taking action to prevent the occurrence of inappropriate practices and/or behaviour.

To the extent that a person suspects or becomes aware of potential wrongdoing they should follow the procedures outlined below.

Confidentiality

People covered by this Policy can raise their disclosure anonymously or ask that their identity not be disclosed. Anonymous disclosures will be investigated to the extent possible, and people who make reports can remain anonymous during and after any investigation. However, an investigation may not be possible unless sufficient information is provided, and it may make it difficult to offer you the same level of practical support if we do not know 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 follow-up on the status of your report and may enable you to receive updates on how FCTG has responded to your report. Please note that it may not always be possible to provide you with updates.

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. If you do provide your name, it will only be disclosed if you provide your consent, or in exceptional circumstances where the disclosure is allowed or required by law. If you have concerns about this, you can discuss this with the whistleblower protection officer, Peter Feros, Group General Counsel. The protections available to whistleblowers under Australian law are available even if you remain anonymous.

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.

The protections offered will depend on things such as the nature of the disclosure and people involved. If you choose to remain anonymous, this will limit FCTG’s ability to offer practical support and protection. If you do provide your name, your report will be handled confidentially. Practical protections may include the following:

  • monitoring and managing the behaviour of other employees;
  • offering you a leave of absence or flexible working arrangements where appropriate; and
  • additional support such as counselling services.

Anonymity

Your identity (and any information FCTG has because of your report that someone could likely use to work out your identity) will only be disclosed if you give your consent to disclose that information or in exceptional circumstances where the disclosure is allowed or required by law (e.g. in dealings with a regulator) or to the extent it is permitted under local applicable law.  It is illegal for a person to identify a discloser that wishes to remain anonymous, outside the circumstances where the disclosure is allowed or required by law.

Reasonable grounds to believe the information is true

You will be expected to have reasonable grounds to believe the information you are disclosing is true, but you will not be penalised even if the information turns out to be incorrect. If a report is made under this Policy, 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. You must not make a report that you know is not true or is misleading. Where it is found that a person has knowingly made a false report, this will be considered a serious matter and will result in disciplinary action.

Reporting concerns

If you have any known or suspected genuine concerns about potential wrongdoing, you should make a disclosure about it. Subject to any notice requirements as set out in your local policies applicable to your employing FCTG entity, your responsibility is to report this concern to:

Enterprise Risk:

If you feel uncomfortable or unable to report your concern to these people, please refer to the notice requirements as set out in your local policies applicable to your employing FCTG entity, or 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. Reports can be made anonymously and/or confidentially, securely and outside of business hours.

Navex Global will take your call or read your online report, consider your concern and undertake an appropriate course of action.

Responding to reports under this Policy

Any disclosures made under this Policy will be received and treated sensitively and seriously, and will be dealt with promptly, fairly and objectively. FCTG’s response to a report will vary depending on the nature of the report and the amount of information provided and subject to local applicable laws relevant to the FCTG entity. Some reports will be resolved informally whereas others may be investigated through a formal process.  Any investigation commenced will be conducted in a timely manner and will be fair and independent from any persons to whom the report relates. All employees and contractors must cooperate fully with any investigations.

When appropriate, a person being investigated or mentioned in a disclosure will be provided with details of the report that involves them (to the extent permitted by local and applicable laws) and be given an opportunity to respond.

Where an investigation identifies a breach of the Company’s Code of Conduct or internal policies or procedures, appropriate disciplinary action will be taken. This may include but is not limited to terminating or suspending the employment or engagement of the person(s) involved in the misconduct.

Where appropriate, 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. You should treat any information shared with you about the investigation as confidential.

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. The Audit and Risk Committee will be provided additional information about any material incidents raised. 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 report should consider whether any action needs to be taken under the Communications and 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 continuously reviewed to ensure they are relevant and appropriate for our workplace.

This Policy will be available on the FCTG public website and on internal policy platforms. This Policy does not form part of the contractual terms of employment and may be amended from time to time.

Related policies and procedures to the extent applicable locally

  • 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

It is the intention that this Policy apply to all FCTG entities globally. In the event of any inconsistency between this Policy and a local law applicable to a FCTG entity, the local law and local policy shall prevail to the extent it is applicable to the employees of the local FCTG entity.

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.