Cameron Facilities is committed to transparency, integrity, and a safe environment for raising concerns.
| Policy Number | CF-GOV-WB-001 |
| Version | 2.0 |
| Effective Date | September 2026 |
| Review Date | September 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:
Who You Can Disclose To
Under section 1317AAC of the Corporations Act 2001 (Cth), a disclosure qualifies for protection when it is made to an eligible recipient. Eligible recipients are defined by the position a person holds, not by name. For Cameron Facilities they are:
- Any officer or senior manager of Cameron Facilities Pty Ltd. This includes the Managing Director and the General Manager, Operations and Growth.
- Any auditor, or member of an audit team, of Cameron Facilities Pty Ltd.
- Any actuary of Cameron Facilities Pty Ltd.
- Any person Cameron Facilities has authorised to receive disclosures that may qualify for protection.
These roles are held by different people over time. A disclosure is made to the role, so it remains a protected disclosure regardless of who occupies the position on the day.
Internal Reporting
You may make a disclosure by any of the following routes. All of them reach an eligible recipient and all of them may be used in confidence.
- In writing, by post. Address your disclosure to The Managing Director, or to The General Manager, Operations and Growth, at 396 Walcott Street, Mount Lawley WA 6050. Mark the envelope Private and Confidential. It will be opened only by the person it is addressed to.
- By telephone. Call +61 8 6154 0910 and ask to speak with the Managing Director, or with the General Manager, Operations and Growth, about a confidential matter. You do not have to give a reason to the person who answers.
- In person. Ask any officer or senior manager for a private conversation. You may bring a support person.
You do not need to use the word whistleblower, cite this Policy, or know whether your concern qualifies for protection. Raising the concern is enough.
If Your Concern Involves a Senior Person
A disclosure is never routed to the person it concerns.
- If the concern involves the Managing Director, direct it to the General Manager, Operations and Growth, who will refer it to an independent external party.
- If the concern involves the General Manager, direct it to the Managing Director.
- If the concern involves both, or you would rather not use an internal route at all, use one of the external channels set out below. Going straight to a regulator or to a legal practitioner does not reduce your protection in any way, and you do not need to raise the matter internally first.
Anonymous Reporting
Cameron Facilities accepts anonymous disclosures, and an anonymous disclosure attracts the same protection under the Corporations Act as a named one. You may stay anonymous when you make the disclosure, throughout the investigation, and afterwards.
An anonymous disclosure may be posted to either role above without a return address. If you would like to receive an outcome while staying anonymous, you may set up a free web based email account under a name that is not your own and provide it as the only contact point. We encourage disclosers to identify themselves where they feel able to, because it lets us seek clarification and tell you what happened, but it is not a condition of protection and it is not a condition of us acting.
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.
Fair Treatment of Individuals Mentioned in a Disclosure
A disclosure is an allegation, not a finding. Cameron Facilities will treat any person who is named in, or is the subject of, a disclosure fairly. We will:
- Handle the disclosure confidentially while it is assessed and investigated.
- Advise that person of the substance of the allegations once doing so will not prejudice the investigation, and give them a reasonable opportunity to respond before any conclusion is reached.
- Keep a written record of that response.
- Advise them of the outcome of the investigation.
- Offer them access to the same wellbeing support available to the discloser.
Fair treatment of a person named in a disclosure does not override the confidentiality owed to the discloser. The identity of a discloser will not be revealed to the person the disclosure concerns.
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:
| Confidential disclosures | By post, marked Private and Confidential, to The Managing Director or The General Manager, Operations and Growth, at the registered address below. Or by telephone on +61 8 6154 0910, asking for that role. |
| General questions about this Policy | [email protected]. Please note this is a shared business inbox and should not be used to make a disclosure. |
| Registered Address | 396 Walcott Street, Mount Lawley WA 6050 |
| Website | www.cameronfacilities.com.au |
Approved by:
The Managing Director
Cameron Facilities Pty Ltd
September 2026
Report A Concern
If you have a genuine concern about misconduct or unethical behaviour, you can raise it in confidence. Write to The Managing Director, or to The General Manager, Operations and Growth, and mark your envelope Private and Confidential. Or call +61 8 6154 0910 and ask to speak with either role about a confidential matter.
Registered Address: 396 Walcott Street, Mount Lawley, WA 6050
You may also go directly to a regulator or to a legal practitioner at any time. You do not have to come to us first.