Whistleblower Policy

Purpose

Acts Global Churches is committed to fostering a Christ-centred culture of integrity, transparency and accountability across all our activities. We believe that raising concerns early—when something does not seem right—helps keep our communities safe, strengthens good governance, and supports the health of our movement.

This Policy outlines how concerns about Acts Global Churches business conduct can be raised, how they will be handled, and the protection available to those who speak up under the Corporations Act 2001 (Cth) and other relevant legislation. Our intention is to create an environment where individuals feel safe, supported and confident to come forward, knowing their information will be treated seriously, respectfully and fairly.

Scope and Application

This Policy applies to current and former:

  • employees and officers;
  • volunteers;
  • contractors, suppliers and their staff (paid or unpaid);
  • associates; and
  • relatives or dependents of any of the above.

These individuals are collectively referred to as Eligible Whistleblowers.

What Can Be Reported

This Policy relates to a specific set of reports or concerns that are protected by Whistleblower protection. A disclosure qualifies for protection when a person honestly believes something isn’t right, even if you can’t prove it (reasonable grounds). This Policy relates to reports for the following matters:

a) Misconduct or an improper “state of affairs” or circumstances

Examples include:
  • dishonest, fraudulent, corrupt or unethical conduct;
  • misuse or misappropriation of funds;
  • significant conflicts of interest;
  • serious breaches of governance or internal controls; or
  • behaviour indicating systemic issues.

b) Breaches of Commonwealth law - This includes potential contraventions of the Corporations Act or offences punishable by 12 months’ imprisonment or more.

c) Conduct creating serious risk - Such as conduct posing a material risk to public health or safety, the environment, or the stability of the financial system.

A whistleblower does not need to prove the allegation for it to be considered.

Matters Not Usually Covered

Some matters are generally not considered whistleblower disclosures, including personal work‑related grievances, such as:

  • interpersonal conflict;
  • decisions about promotions or performance management;
  • decisions about engagement or termination that do not involve breaches of law.

These concerns will usually be managed through the Complaints and Grievances Policy (COM001) or other relevant internal processes. However, personal grievance may still qualify for protection if it also involves misconduct, legal breaches or victimisation related to whistleblowing.

How to Report a Concern

Individuals may report concerns anonymously or with their identity disclosed. Doing so directly to those specific people outlined in this policy ensures your report can be legally protected. The specific avenues for raising your concerns are as follows:

a) Internal Reporting Channels

Whistleblowers are encouraged to report internally where they feel safe to do so, as this enables swift action and early resolution.

b) External Reporting Channels

Whistleblowers can also report directly to any relevant body such as:

Protections Available to Whistleblowers

When a disclosure qualifies for protection, the whistleblower receives:

a) Confidentiality

Their identity will not be shared except where required by law or with their consent.

b) Protection From Detriment

No one may cause or threaten harm, disadvantage, intimidation or discrimination because a concern has been raised.

c) Immunity

Whistleblowers are not liable for civil, criminal or administrative consequences arising from making the disclosure.

d) Compensation and Remedies

Whistleblowers may seek legal remedies if they experience victimisation.

To support individuals who speak up, Acts Global Churches takes steps such as:

  • limiting who has access to information;
  • securing documents and records;
  • adjusting duties or work arrangements to reduce risks of detriment;
  • offering pastoral care or wellbeing support.

Support is guided by sensitivity, discretion and the wellbeing of all parties involved.

Responding to Concerns

The following outlines what to expect from Acts Global Churches in responding to concerns covered by this Policy.

a. Receipt and Acknowledgement

The Whistleblowers Protection Officer (WPO) or delegate will acknowledge the disclosure, outline the process and provide reassurance about confidentiality.

b. Assessment and Triage

The matter will be promptly assessed to determine whether it qualifies for protection, the level of risk, urgency and the most suitable investigative approach.

c. Investigation

Investigations will be handled respectfully, objectively and promptly. A qualified investigator—internal or external—may be appointed depending on the nature and complexity of the matter.

d. Procedural Fairness and Outcomes

Acts Global Churches is committed to fairness for all individuals involved. This includes giving those named in a disclosure an opportunity to respond, where appropriate and safe.

At the conclusion of an investigation, Acts Global Churches will determine next steps, which may include remediation, disciplinary action, system improvements or reporting to relevant authorities. Where possible, the whistleblower will be provided with a general update on the outcome.

e. Review of Investigation

A whistleblower may request a review of the investigation process. Acts Global Churches may decline to reopen a matter if it was conducted appropriately or if no new information is available. Whistleblowers may also contact authorities if they remain unsatisfied with the outcome.

Confidentiality and Anonymity

Anonymous disclosures are accepted. However, anonymity may limit the ability to investigate fully.

Information that may identify the whistleblower will only be shared where:

  • required by law (e.g., ASIC, APRA etc), or
  • the whistleblower has provided consent.

Acts Global Churches will always take reasonable steps to minimise the risk of identification. This is through secure and dedicated mailboxes and secure information storage and deidentification where required and appropriate.

False, Vexatious or Malicious Reports

Knowingly making a false or malicious allegation is a serious matter and could result in disciplinary action. However, a disclosure made in good faith remains protected even if it is not substantiated.

Governance, Oversight and Review

The Acts Global Churches Board oversees this Policy to ensure it remains effective and accessible. The Policy will be reviewed every two years, or earlier if needed.

Related Policies and Documents

  • Complaints and Grievances Policy (COM001)
  • Privacy Policy (COM003)
  • Records Keeping Policy (COM004)
  • Ministers Code of Conduct

This Policy aims to support a culture where people can speak up with confidence, knowing they will be protected, respected and heard.