Protected disclosure policy
REPORTING IMPROPER CONDUCT (WHISTLEBLOWING) POLICY
1. Commitment to Ethical Conduct
United Nationals Countryless Children (UNCC) is committed to the highest standards of legal, ethical, and moral behavior in all its operations.
We believe integrity and accountability are essential to building trust with our donors, beneficiaries, partners, and the public.
A key part of maintaining these standards is empowering people to speak up safely about misconduct, wrongdoing, or unethical behaviour without fear of retaliation.
2. What Can Be Reported
Improper conduct includes, but is not limited to:
-
Illegal, dishonest, fraudulent, or corrupt activities;
-
Breach of trust, negligence, or failure of duty;
-
Unethical or dishonest behaviour;
-
Misuse or mismanagement of UNCC funds or resources;
-
Unsafe practices that could harm people or the environment.
-
Behavior that could damage UNCC’s reputation or interests;
-
Breaches of legislation, policy, or governance standards;
-
Serious misconduct, harassment, discrimination, or abuse of power.
All reports will be treated seriously, assessed promptly, and managed confidentially.
3. Protection for Whistleblowers
UNCC provides strong protections for individuals who make reports in good faith.
No person will be penalised, dismissed, demoted, or discriminated against for raising a legitimate concern.
Anonymous reports are accepted, and confidentiality will be maintained to the fullest extent possible under the law.
This protection applies to:
-
UNCC staff, volunteers, and contractors;
-
Board and committee members;
-
Donors, suppliers, and partners;
-
Members of the public engaged with UNCC programs.
4. How to Report Improper Conduct
Reports may be made to any eligible recipient within UNCC or through our independent whistleblowing service.
Eligible Recipients at UNCC
-
Head of Risk – UNCC
-
Chair of the Board – UNCC
-
Chair of the Audit and Risk Committee – UNCC
-
Executive Director / CEO – UNCC
5. Independent Reporting
Individuals may also report misconduct anonymously and confidentially through UNCC’s secure online reporting platform:
www.uncc.agency → Contact Us – Whistleblower Reporting Portal
Reports submitted through this system are automatically directed to UNCC’s Head of Risk and, where appropriate, to the Chair of the Audit and Risk Committee for independent oversight.
6. Investigation Process
-
Acknowledgement: The reporter will receive confirmation (where contact details are provided) that their report has been received.
-
Assessment: The Head of Risk will assess the allegation and determine whether it qualifies as a protected disclosure.
-
Investigation: A fair and impartial investigation will be undertaken by internal or external investigators.
-
Outcome: Findings will be reported to the Board and, where applicable, corrective action will be taken.
-
Feedback: The reporter may be updated on the outcome, subject to privacy and legal considerations.
7. Confidentiality and Anonymity
All reports will be treated with strict confidentiality.
UNCC respects the right of individuals to remain anonymous.
Information will only be shared with those directly involved in handling or investigating the report.
8. False or Malicious Reports
Reports made in bad faith or with the intent to cause harm may result in disciplinary action.
However, individuals who make reports in good faith will always be protected, even if the allegations are not substantiated.
9. Legal Basis
This policy aligns with:
-
Corporations Act 2001 (Cth), Part 9.4AAA (Whistleblower Protections)
-
Australian Charities and Not-for-profits Commission (ACNC) Governance Standards
-
Public Interest Disclosure principles for charities and not-for-profits
10. Review and Approval
This policy will be reviewed every two (2) years or earlier if required by legislative changes or governance updates.
Any amendments must be approved by the UNCC Board of Directors.
Board Approval
Approved By:
Chairperson, Board of Directors – UNCC
Date: 01/01/2025
Endorsed By:
Executive Director / Chief Executive Officer – UNCC
Date: 01/01/2025
Next Review Date: 2028