August 2026
The purpose of this Whistleblowing Policy (Policy) is to document the commitment of Future Group Australia Holdings Pty Ltd, a corporate group consisting of several wholly owned subsidiaries (together referred to in this document as Future Group) to supporting potential whistleblowers. It sets out the reporting framework and protections in place for individuals to report serious misconduct or an improper state of affairs or circumstances.
This Policy is underpinned by our commitment to promote a culture and workplace environment that supports the physical and psychological health and wellbeing of our staff in the workplace, and the way that they interact with our members and clients.
This Policy applies to all of Future Group’s ‘eligible whistleblowers’ as defined in s1317AAA and ‘eligible recipients’ as defined under s1317AAC of the Corporations Act (2001). These terms are explained in later sections of this Policy.
The Policy sets out the system for reporting, investigating and handling wrongdoing that may not be uncovered unless there is a safe and secure means for disclosing the wrongdoing, and articulates how such reports will be dealt with fairly, confidentially and impartially by Future Group. By reporting wrongdoing, you can ensure people are secure and safe in our work environment and help us detect fraud and misconduct. This enables us to reinforce a consistent culture of proactive risk management and strong corporate governance that our people, members and regulators can rely upon.
The Policy also provides clarity on how Future Group supports Reporters so that they:
Future Group values and provides a safe environment for reporting wrongdoing. Future Group will treat each report received as serious and will take all reasonable steps to protect and support the Reporter. Future Group will not tolerate detrimental treatment of any person who has made, or is considering making, a report under this Policy.
The content of this Policy has been written to align with the obligations contained in:
There are also specific protections provided in the tax whistleblower regime as outlined in Part IVD of the Taxation Administration Act 1953. Whilst these provisions are not specifically referenced in this Policy, reports received which include a tax element will be considered with reference to the provisions.
A copy of this Policy is made available to all staff on a shared drive and to other eligible whistleblowers on the Future Group website. If material changes are made to this Policy, these changes are communicated to all staff by the most appropriate means in the given circumstances, and a copy of the revised document is made available.
Training will be provided to staff to ensure they are aware of their responsibilities.
Persistent and conscious failure by staff members to act in accordance with this Policy is considered a serious disciplinary matter and corrective action will be determined by Future Group on a case-by-case basis.
This Policy is reviewed at least every two years. An ad hoc review of this Policy may be triggered outside of the regular review timetable if:
a) If there is a significant change to the size, business mix, or complexity of business operations;
b) If there is a significant change in relevant legislation, regulatory requirements or prudential standards and guidance; or
c) At any other time on the request of the Future Group Board (FG Board).
The findings of any review, and the action taken and/or planned to address issues identified in the review process, will be reported to the Future Group Board.
In accordance with s1317AAA of the Corporations Act, an individual is considered to be an Eligible Whistleblower of Future Group if they are, or have been, any of the following:
a) An officer of Future Group.
b) An employee of Future Group.
c) A supplier of services or goods (including their employees) to Future Group.
d) An associate of Future Group.
e) A relative, dependant or spouse of an individual listed above.
As Future Group provides services to a superannuation entity, the following are also considered to be an Eligible Whistleblower:
f) An individual (and their employees) who is a trustee, custodian or investment manager of the superannuation funds Future Group supports.
g) An officer of a body corporate that is a trustee, custodian or investment manager of the superannuation funds Future Group supports.
If you are an eligible Future Group whistleblower as set out in section 2, the following criteria must be met to access the legal rights and protections for whistleblowers in the Corporations Act. Where all the following criteria are met, the issue being reported is known as a ‘disclosable matter’:
a. A Future Group company, or
b. an organisation Future Group has provided goods or services to, or
c. an associate of Future Group
You must make your disclosure to an eligible recipient – see section 4
You must have reasonable grounds to suspect that the information you are disclosing about the company or organisation concerns:
a. Misconduct, or
b. An improper state of affairs or circumstances
This information can be about the company or organisation, or an officer or employee of the company or organisation, engaging in conduct that:
'Reasonable grounds' means that a reasonable person in your position would also suspect the information indicates misconduct or a breach of the law.
There are additional protections if concerns relate to matters in the public interest or an emergency.
Refer to the associated Whistleblower Procedures available on the staff intranet for examples of disclosable matters.
Reports of disclosable matters must be made to one of the following Eligible Recipients to qualify for the whistleblower protections:
*A senior manager includes any member of Future Group’s Executive Leadership Team and the General Legal Counsel.
To facilitate investigations of disclosable matters, Future Group would prefer that a Reporter (of an Eligible Disclosure) makes a report openly and discloses their identity. However, it is understood that any person who has reasonable grounds to suspect that a disclosable matter has occurred and is apprehensive about raising their concern because of the fear of possible adverse repercussions, can make a report anonymously.
A Reporter considering making a report must have reasonable grounds for believing the disclosure is a disclosable matter. A Reporter will be given the opportunity to provide evidence in relation to the disclosable matter but is not required to prove their allegations.
This Policy is intended to apply to disclosable matters which are serious in nature. Unsubstantiated reports that are trivial, vexatious, made maliciously or known to be false will be viewed seriously and may be subject to disciplinary action.
Future Group has engaged the services of YourCall, a professional organisation providing whistleblowing support services. A Reporter can make an eligible disclosure through Your Call as an alternative to an individual set out in section 4.
Your Call provides a secure whistle-blower service. Making a report to Your Call allows the Reporter to remain completely anonymous, to identify themselves only to Your Call, or to identify themselves to both Your Call and Future Group.
Your Call contact options:
After making a disclosure to Your Call, the Reporter will be provided with a unique Disclosure Identification Number (DIN) and access to a secure online Message Board. The Message Board allows ongoing anonymous communication with Your Call and/or Future Group. Your Call always remains the intermediary, receiving and forwarding communication between all parties. The Message Board can be used to receive updates, share further information/evidence and request support or report retaliation.
If the Message Board cannot be accessed, Your Call will provide verbal updates by phone.
Where possible, Future Group requests reports be made in writing, to ensure the information provided by the Reporter is captured correctly. However, reports can be provided in any manner as long as they are provided to an Eligible Recipient as set out in section 4.
A Reporter should advise whether they wish to remain anonymous, or for their identity to be known only to the Eligible Recipient. Future Group recommend the following information is provided, or as much detail as the Reporter is able to provide about the disclosable matter:
a) An explanation of the disclosable matter.
b) The names of any persons involved in the disclosable matter.
c) The names of any persons who witnessed the disclosable matter.
d) Dates, times and locations of when the disclosable matter was observed.
e) Specific details of any transactions involved.
f) Any other details of the disclosable matter, including evidence in the form of documents or emails, and information about financial or non-financial loss.
All disclosures of disclosable matters by a Reporter will be treated in the strictest of confidence and all reasonable steps will be taken to protect the identity of the Reporter.
A Reporter can choose to remain anonymous while making a report, over the course of the investigation and after the investigation is finalised. A Reporter can refuse to answer questions that they feel could reveal their identity at any time, including during follow-up conversations. Future Group strongly encourages a Reporter who wishes to remain anonymous to maintain ongoing, anonymous communication with Future Group to allow follow-up questions to be asked.
The Reporter must generally provide their consent before any information can be shared or discussed as part of the investigation into their report.
The content of the report will not be discussed with anyone without the Reporter’s consent (exceptions apply, see below), other than those who need-to-know for the purposes of investigating the issues raised in the report, and all reasonable steps will be taken to protect the identity of the Reporter (unless the Reporter provides consent in writing for their identity to be revealed). This also includes taking reasonable precautions to ensure that any reported disclosures (physical or electronic) are stored securely with restricted access by authorised personnel only.
Unauthorised disclosure of information relating to a report or of the identity of the Reporter will be regarded seriously and may result in disciplinary action. Civil and criminal penalties under the Corporations Act may also apply.
Information about a Reporter’s identity or information that is likely to lead to the identification of a Reporter, may only be disclosed in the following circumstances:
a) Where the information is disclosed to APRA or ASIC or a member of the Australian Federal Police;
b) Where the information is disclosed to a legal practitioner for the purpose of obtaining legal advice for Future Group in respect of the operation of applicable whistleblowing protection laws; or
c) Where the Reporter consents to the disclosure.
Information contained in a report can be disclosed without the Reporter’s consent provided that:
a) The information does not include the Reporter’s identity;
b) All reasonable steps have been taken to reduce the risk that the Reporter will be identified from the information (i.e. by removing possible identifying details); and
c) The information is reasonably necessary to allow for investigation of the issues raised in the report.
Disclosures of disclosable matters may be protected by law and Future Group will strive to ensure confidentiality in the investigation and the protection of the Reporter’s identity.
The types of protection that Future Group will make available will depend on the situation but may include:
a) Monitoring and managing the behaviour of other Future Group staff who are related to the disclosable matter.
b) Offering a paid leave of absence or flexible working arrangements while the conduct is investigated.
c) Rectification of any detriment the Reporter may have suffered as a result of the report/investigation.
We will look for ways to support all Reporters, but we will not be able to provide non-employees with the same type and level of support that we can provide to employees (for example, because we cannot offer flexible workplace arrangements to a supplier). In such cases, we will still seek to offer as much support as practicable.
A Reporter who has reasonable grounds to believe that there is a disclosable matter, and who has not engaged in the disclosable matter, should not be subject to any form of personal disadvantage resulting from having made, or considering making, a disclosure of a disclosable matter, such as:
If the Reporter has been involved in the disclosable matter, they may be subject to disciplinary or remedial action because of any investigation. Although the act of making a disclosure of a disclosable matter will not in itself protect the Reporter from the consequences of improper conduct in which they may have been involved, active cooperation in any investigation, admission and remorse may potentially mitigate any disciplinary action that may be taken against the Reporter.
Future Group will not tolerate a Reporter who reports or considers reporting a disclosable matter, being subjected to harassment, retaliation or adverse consequences. A claim of such treatment will be regarded seriously. Any person who engages in taking adverse action may be subject to disciplinary action (including but not limited to termination of employment or engagement). In some circumstances, this may also be a criminal offence punishable by imprisonment and we may refer the matter to law enforcement authorities for investigation.
Within 48 hours of a report being received by an Eligible Recipient, and subject to consent being given by the Reporter to disclosure of their report and identity:
a) The Whistleblower Investigation Officer will be provided with the report;
b) A Protection Officer will be appointed to the Reporter; and
c) The Chief Executive Officer (or an alternate Senior Executive) will be notified that a report has been received (but will not be given access to the content of the report).
If the Reporter consents to disclosure of their report, but does not consent to their identity being disclosed, the recipient of the disclosure must only disclose to the Whistleblower Investigation Officer information that is reasonably necessary for the purposes of investigating the report. All reasonable steps must be taken to reduce the risk of the Reporter being identified from this information. A Protection Officer will not be appointed.
An initial case assessment will be made by the Whistleblower Investigation Officer, and a decision will be made as to whether to formally investigate the report or to take no further action. In circumstances where the Reporter is anonymous and has not provided a means of contact, further investigation may not be possible. Where the Reporter is contactable, the Whistleblower Investigation Officer may request the Reporter to clarify or provide further information to assist this decision-making process.
If the disclosure is assessed as requiring investigation, the Whistleblower Investigation Officer must immediately escalate the matter (with or without identifying details depending on the consent received) to the attention of the Chief Executive Officer (or an alternate). If the CEO is implicated by the disclosure, the matter should be escalated to Future Group’s General Legal Counsel.
A high-level summary of the disclosure (with no identifying details) will be provided to the FG Risk, Audit & Compliance Committee.
The Whistleblower Investigation Officer will contact the Reporter to acknowledge receipt of a disclosure, assess whether the disclosure comprises a disclosable matter, provide updates as the investigation progresses and is concluded, and where appropriate, notify the Reporter of the outcome.
If the disclosure is assessed as requiring investigation, the Whistleblower Investigation Officer is responsible for managing the investigation, or allocating the matter to an appropriately qualified and suitable Investigator (either within Future Group or an external appointment) and overseeing the investigation.
Depending on the matter and the level of anonymity requested, the identity of the Reporter and those implicated in the matter may be withheld from the Investigator. If the Reporter has not consented to disclose their identity, the Investigator must also be required to take reasonable steps to reduce the risk of the Reporter being identified because of the investigation.
The objectives of the investigation will be to:
a) Collate information relating to the allegations of a disclosable matter as quickly as possible;
b) Consider the information collected; and
c) Draw a conclusion as to whether or not the disclosable matter is legitimate based on the evidence provided in an objective and impartial manner.
All investigations are required to comply with the principles of natural justice and procedural fairness. The investigation must be conducted without bias and the entity or person(s) against whom the allegation is made must be given a fair opportunity to respond. The investigation must be fully documented and conducted in a timeframe which is reasonable given the circumstances.
The Reporter will be provided with regular updates in relation to the investigation (if they are able to be contacted, including through anonymous channels). The timeframe may vary depending on the nature of the report. In some circumstances, it may not be appropriate to provide details of the outcome to the Reporter.
All Future Group staff are required to treat the investigation in absolute confidence. Any Future Group staff member revealing the presence of an investigation or details contrary to this Policy may be subject to disciplinary action.
Subject to any statutory confidentiality limitations, at the conclusion of the investigation the Investigator must prepare a written report detailing the matter, the findings, the reasons for the findings, and the rectification actions implemented or recommended for implementation.
Where the report indicates that a disclosable matter has not occurred, the Whistleblower Officer will refer the matter to the Chief Executive Officer (for implementation of any actions that may be required in light of the report).
Where the report indicates that a disclosable matter has occurred, the Whistleblower Officer will refer the matter to the Chief Executive Officer for discussion and decision in respect of the steps to be taken to remedy any harm or loss arising from the conduct (including disciplinary proceedings or referral of the matter to the appropriate authorities) and the actions to be taken to prevent the conduct from occurring again in the future. Any documents pertaining to the report, including subsequent investigations, findings, recommendations and meeting minutes, will be kept securely by the Investigator.
No disciplinary action will be taken against any Future Group staff who are implicated in a disclosure under this Policy until an investigation has determined whether any allegations against them are substantiated.
However, a Future Group staff member who is implicated may be stood down on full pay whilst an investigation is in process or may be temporarily transferred to another office or workplace, if Future Group determines that it is appropriate, given all the circumstances, to do so. If the investigation determines that the allegations are not substantiated, the Future Group Representative must be immediately reinstated to full duties.
Any disclosures that implicate a Future Group staff member must be kept confidential, even if the Reporter has consented to the disclosure of their identity, and should only be disclosed to those persons who have a need to know the information for the proper investigation of the disclosure.
A Future Group staff member who is implicated in a disclosure has a right to be informed of the allegations against them and must be given an opportunity to respond to those allegations and provide additional information, if relevant, during an investigation into those allegations (subject to the Reporter’s right to anonymity as set out in this Policy and applicable laws).
