Effective Date: 1 January 2025
Version: 3.0 — Ultra-Final (Djenie Edition)

1. PURPOSE

This Whistleblower Policy establishes protected, confidential, and safe reporting channels for individuals to disclose suspected misconduct relating to In Delay There Lies No Plenty Pty Ltd ACN 162 881 138 ATF Future Thinking Family Trust t/a Djenie ABN 98 399 797 036 (“Djenie”).
It aligns with:

  • Corporations Act 2001 (Cth) Part 9.4AAA
  • ASIC Regulatory Guide 270
  • Fair Work Act 2009
  • Australian Privacy Act 1988 (APPs)
  • UK FCA & EU Whistleblowing Directive principles
  • U.S. SEC/DOJ whistleblower norms
  • Singapore PDPA reporting expectations

Djenie extends protections to any individual making a good-faith disclosure.

2. SCOPE

Eligible whistleblowers include:

  • employees, contractors, consultants
  • volunteers and former staff
  • suppliers and subcontractors
  • relatives or dependants of any of the above

3. DISCLOSABLE MATTERS

Protected disclosures include:

  • breaches of law or regulations
  • fraud, bribery, corruption, theft, or misuse of funds
  • harassment, discrimination, bullying, victimisation
  • data misuse, privacy breaches, cybersecurity failures
  • WHS risks or endangerment to individuals
  • unethical conduct, conflicts of interest, governance failures
  • systemic wrongdoing within Djenie systems or operations
    Excluded unless systemic:
  • personal employment grievances

4. PROTECTIONS FOR WHISTLEBLOWERS

4.1 Confidentiality

Your identity will not be disclosed without consent except:

  • to ASIC, APRA, AFP, or legal advisers
  • where required by law

4.2 Protection from Detriment

Prohibited actions include:

  • dismissal, demotion, discrimination
  • intimidation, threats, harassment
  • reputational damage
  • adverse changes to working conditions

4.3 Immunity

Whistleblowers are protected against civil, criminal, or administrative liability for making a protected disclosure.

5. REPORTING CHANNELS

Internal Reporting:

External Reporting (Australia):

  • ASIC
  • APRA
  • AFP
  • Qualified legal practitioners

International Reporting (where relevant):

  • UK regulators (FCA)
  • EU national authorities under the EU Directive
  • U.S. SEC, DOJ, CFPB
  • Singapore PDPC

6. HANDLING OF DISCLOSURES

Djenie will:

  • acknowledge the report within 7 days (if contact provided)
  • assess whether the disclosure is protected
  • initiate a fair, confidential investigation
  • maintain strict identity protection protocols
  • provide outcome updates where legally appropriate
  • implement corrective actions and systemic fixes

7. SUPPORT & PROTECTION MEASURES

Djenie may provide:

  • counselling referrals
  • flexible work or role adjustments
  • workload support
  • active monitoring for victimisation

8. FALSE OR MALICIOUS DISCLOSURES

Knowingly false disclosures may result in appropriate action.
Good-faith disclosures remain protected, even if unsubstantiated.

9. ROLES & RESPONSIBILITIES

Chief Executive Officer:

  • overall governance and whistleblower protection

Privacy Lead:

  • identity protection
  • secure storage of disclosures

Security & Compliance:

  • investigative support

All Employees:

  • must cooperate in investigations
  • must not victimise or retaliate

10. RECORD KEEPING & PRIVACY

Records are:

  • securely stored
  • access-restricted
  • retained for seven years
  • redacted where possible to minimise personal information

11. REVIEW OF THIS POLICY

Annual review or earlier where regulatory changes or operational needs arise.

12. CONTACT

Whistleblower Support: whistleblower@djenie.com
CEO: ceo@djenie.com
Privacy Lead: privacy@djenie.com

VERSION CONTROL & GOVERNANCE

Version: 3.0 — Ultra-Final (Djenie Edition)
Effective Date: 1 January 2025
Approval: Chief Executive Officer, Djenie
Change Summary: Full rewrite for Djenie’s operational, legal, and organisational structure; replaced all Cushi references; strengthened identity protection and global pathways.
Review Cycle: Annual or earlier if required.