Whistleblower Policy

Purpose

This policy establishes Westlink Logistics’ framework for the protection and support of individuals who disclose wrongdoing, in accordance with the Corporations Act 2001 (Cth) Part 9.4AAA and the Taxation Administration Act 1953 (Cth). It ensures eligible whistleblowers can report disclosable matters without fear of reprisal and that all disclosures are investigated in a timely, fair, and confidential manner.

Scope

This policy applies to all current and former officers, workers, contractors, suppliers, associates, and their relatives and dependants of Westlink Logistics. It covers disclosures relating to misconduct, illegal activity, or an improper state of affairs concerning Westlink Logistics or any related body corporate. Personal work-related grievances are addressed under GOV-POL-011 unless they also involve a contravention of law.

Organisational Context

Westlink Logistics operates heavy haulage, project logistics, and maritime services across Australia, primarily supporting defence, government, resources, and infrastructure sectors. The organisation manages government contracts, security-classified information, and complex supply chains where early disclosure of misconduct protects both public interest and organisational integrity.

The organisation holds DISP membership and is subject to JOSCAR pre-qualification, both of which require demonstrated governance standards. While Westlink is not a listed company, it is a proprietary company subject to the Corporations Act whistleblower provisions. This policy also supports the reporting of security-related concerns that may arise under DISP obligations.

Policy Commitments

Westlink Logistics encourages the reporting of suspected unethical, illegal, corrupt, or fraudulent conduct and is committed to:

• Maintaining reporting channels accessible to all eligible whistleblowers: the CEO and Board of Directors as eligible recipients, the QHSE Manager as authorised internal contact, and external bodies including ASIC, ATO, and other prescribed authorities. Disclosures need not be in writing.

• Protecting the identity of disclosers as required by the Corporations Act. Identity information will only be disclosed to ASIC, APRA, the AFP, a legal practitioner, or with the discloser’s consent. Breach of confidentiality is a criminal offence.

• Prohibiting detrimental conduct against disclosers including dismissal, demotion, harassment, intimidation, discrimination, damage to reputation, or any other retaliation. Disclosers have immunity from civil, criminal, or administrative liability for making a qualifying disclosure.

• Investigating all disclosures in a fair, objective, and timely manner with procedural fairness for both the discloser and the subject. Where a breach of law is identified, referring the matter to the relevant regulatory authority or law enforcement.

• Storing all whistleblower records securely with access restricted to those directly involved in receipt, assessment, or investigation. Records are maintained per GOV-SCH-001.

Disclosable matters include offences against the Corporations Act, offences punishable by 12+ months imprisonment, dangers to the public or financial system, breaches of WHS or environmental legislation, fraud, bribery, corruption, modern slavery, and breaches of fiduciary duty. Emergency disclosures (substantial and imminent danger) and public interest disclosures may be made to journalists or parliamentarians subject to the conditions in Part 9.4AAA.

Responsibilities

Role	Responsibility	When
Chief Executive Officer	Accountable for this policy. Eligible recipient for disclosures. Ensures adequate systems and resources for whistleblower protection. Appoints alternative investigator where required.	Ongoing; on disclosure received
Board of Directors	Eligible recipients for disclosures. Receive investigation outcomes. Oversight of policy effectiveness.	On disclosure; annual review
QHSE Manager	Authorised internal whistleblower contact. Coordinates investigations. Maintains the whistleblower disclosure register. Ensures eligible recipients are trained.	On disclosure; ongoing training
Managers and Supervisors	Support a culture where workers feel safe to raise concerns. Direct potential disclosures to eligible recipients.	Ongoing; on concern raised
All Workers, Contractors, and Suppliers	Report suspected wrongdoing through the channels identified in this policy.	On suspicion of misconduct

Review

This policy is reviewed annually as part of the management review cycle, or when significant changes occur to applicable legislation or the nature of disclosures received. This policy is made available to all officers, workers, contractors, and suppliers of Westlink Logistics.

Applicable Standards and Legislation

• Corporations Act 2001 (Cth)

• Taxation Administration Act 1953 (Cth)

• ASIC Regulatory Guide 270 — Whistleblower Policies

• ISO 9001:2015 Quality Management Systems — Requirements

Related Documents

• GOV-POL-011 Grievance Resolution Policy

• GOV-POL-012 Anti-Bribery and Corruption Policy

• GOV-POL-013 Modern Slavery Policy

• GOV-POL-019 Gifts, Hospitality and Conflicts of Interest Policy

• QHSE-MAN-001 Westlink Management System Manual