Whistleblowing Policy

Cameron Facilities is committed to transparency, integrity, and a safe environment for raising concerns.

Policy Number CF-GOV-WB-001
Version 1.0
Effective Date April 2026
Review Date April 2027
Policy Owner Managing Director
Applies To All employees, contractors, subcontractors, and suppliers

Purpose

Cameron Facilities Pty Ltd (Cameron Facilities) is committed to operating with integrity, transparency, and accountability across all aspects of its business. This Whistleblowing Policy establishes a formal framework that encourages individuals to report genuine concerns about misconduct, unethical behaviour, or wrongdoing, without fear of retaliation or adverse consequences.

This Policy reflects our values as an organisation and our obligations under the Corporations Act 2001 (Cth), the Public Interest Disclosure Act 2003 (WA), and applicable Australian workplace laws.

Scope

This Policy applies to:

  • All employees of Cameron Facilities, whether full-time, part-time, or casual
  • Contractors, subcontractors, labour hire workers, and volunteers
  • Suppliers and their employees who have dealings with Cameron Facilities
  • Former employees and associates who have information about misconduct

This Policy covers conduct occurring in connection with the work, business, or operations of Cameron Facilities, including its managed sites across Western Australia and the Northern Territory.

What can be reported

A disclosable matter is any genuine concern about conduct that falls into one or more of the following categories:

Misconduct and Unethical Behaviour

  • Fraud, theft, financial misappropriation, or corruption
  • Bribery or undisclosed conflicts of interest
  • Falsification of records, invoices, timesheets, or compliance documents
  • Deliberate breach of Cameron Facilities policies or procedures

Workplace Safety

  • Unsafe work practices or failure to comply with WHS obligations
  • Concealment of accidents, incidents, or near-misses
  • Failure to maintain required licences, certifications, or insurances

Legal and Regulatory Breaches

  • Breaches of environmental, employment, or contracting laws
  • Discrimination, harassment, or bullying that has not been properly addressed
  • Conduct that constitutes an offence under Australian law

Governance Failures

  • Misuse of company assets or information
  • Failure to disclose material information to clients or regulatory bodies
  • Any other conduct that poses a serious risk to our people, clients, or reputation

This Policy is not intended to address ordinary workplace grievances (such as pay disputes or performance feedback), which should be directed through standard HR channels.

How to Make a Disclosure

Cameron Facilities provides multiple reporting channels to ensure accessibility and confidentiality:

Internal Reporting

Reports may be made directly to:

  • Managing Director: Sherif Sulejman — sherif@cameronfacilities.com.au
  • General Manager, Operations and Growth: Gordon Bryden — gordon@cameronfacilities.com.au

If the concern involves either of the above individuals, the reporter may contact an independent external channel.

Anonymous Reporting

Cameron Facilities accepts anonymous disclosures. Anonymous reports should be submitted in writing to the managing director or general manager, and they will be assessed based on the information provided. While anonymity is respected, we encourage reporters to identify themselves so that we can communicate outcomes and seek clarification where necessary.

External Reporting

Nothing in this Policy prevents an eligible whistleblower from making a protected disclosure to a regulatory body, including:

  • Australian Securities and Investments Commission (ASIC)
  • Australian Prudential Regulation Authority (APRA)
  • The Australian Taxation Office (ATO)
  • WorkSafe WA or NT WorkSafe (for safety matters)
  • A legal practitioner (for the purpose of obtaining legal advice)

Protections for Whistleblowers

Cameron Facilities is committed to protecting individuals who make disclosures in good faith. The following protections apply:

Confidentiality

The identity of a whistleblower will not be disclosed without the individual’s consent, unless required by law. All reports and related information will be handled on a strict need-to-know basis.

Protection from Retaliation

No person who discloses in good faith will suffer any of the following as a result:

  • Dismissal, demotion, or reduction in duties
  • Disciplinary action, harassment, or intimidation
  • Discrimination in any form
  • Damage to professional reputation or working relationships

Any person found to have subjected a whistleblower to retaliation will face disciplinary action, up to and including termination of employment or engagement.

Legal Protections

Where disclosures qualify as protected under the Corporations Act 2001 (Cth) or other applicable legislation, the whistleblower is entitled to immunity from civil and criminal liability in relation to the disclosure.

Investigation Process

Cameron Facilities will investigate all disclosures that are received in good faith and contain sufficient information to act upon. The investigation process will:

  • Be conducted promptly, thoroughly, and impartially
  • Maintain confidentiality throughout, with information shared only on a need-to-know basis
  • Be led by the Managing Director or a nominated independent investigator where appropriate
  • Aim to provide feedback to the discloser on outcomes, subject to confidentiality obligations

Where a disclosure relates to the Managing Director, the investigation will be escalated to an independent external party or legal adviser.

Timelines: We aim to acknowledge receipt of a disclosure within five (5) business days and provide an update on investigation progress within twenty (20) business days. Complex matters may take longer and the discloser will be kept informed.

False or Malicious Reports

This Policy is designed to facilitate genuine and good-faith disclosures. Reports that are found to be intentionally false, frivolous, or made with malicious intent will not be protected under this Policy, and the person making such a report may be subject to disciplinary action.

Awareness and Training

Cameron Facilities will ensure that:

  • This Policy is accessible to all employees and contractors, including via the Cameron Facilities website (www.cameronfacilities.com.au)
  • All new employees are made aware of this Policy during their induction
  • Existing staff receive periodic reminders and training on their rights and responsibilities under this Policy
  • Managers and supervisors understand their obligations to support and not impede disclosures

Policy Review

This policy will be reviewed annually by the managing director, or more frequently where there are significant changes to legislation, operations, or business structure. The Cameron Facilities website will always provide access to the current version of this Policy.

Contact and Further Information

For questions about this policy or to make a disclosure, please contact us:

 

Managing Director Sherif Sulejman | sherif@cameronfacilities.com.au
General Manager Gordon Bryden | gordon@cameronfacilities.com.au
Registered Address 396 Walcott Street, Mount Lawley WA 6050
Website www.cameronfacilities.com.au

Approved by:

Sherif Sulejman

Managing Director, Cameron Facilities Pty Ltd

April 2026

Report A Concern

If you have a genuine concern about misconduct or unethical behaviour, please contact us confidentially using the details below.

Managing Director: Sherif Sulejman — sherif@cameronfacilities.com.au

General Manager: Gordon Bryden — gordon@cameronfacilities.com.au

Registered Address: 396 Walcott Street, Mount Lawley, WA 6050