Qscan Group inclusive of all business units, have a commitment to be the premier radiology specialist provider for its Patients and Referrers.
Qscan encourages reporting any behaviour, conduct or affairs that is inconsistent with Qscan’s Core Values and expected standards of conduct and behaviour. Qscan will not tolerate anyone being discouraged from reporting improper conduct or being subject to detriment because they want to report improper conduct, or they have done so.
The purpose of this Policy is to ensure appropriate management of protected disclosures is adhered to and aims to define the following:
This policy applies to all eligible whistleblowers. Per the Corporations Act, an individual is an eligible whistleblower in relation to a regulated entity if the individual is, or has been, any of the following:
This policy reflects Australian law. Further information regarding the protections afforded under Australian law to persons who make a report is available in Attachment 1 of this policy.
For the avoidance of doubt, this policy applies to protected disclosures as per law, and not to workplace grievances or disputes (please refer to the Grievance and Despite Policy for further information).
You should provide as much information as possible when reporting improper conduct, including details of the improper conduct, people involved, dates, locations and if any more evidence may exist. Disclosers do not have to prove their allegation(s).
When making a report, you will be expected to have reasonable grounds to believe the information you are reporting is true, but you will not be penalised even if the information turns out to be incorrect. Obviously, you must not make a report that is known to be untrue or misleading. Where it is found that a person has knowingly made a false report, this will be considered a serious matter and may result in disciplinary action.
Chris Munday, Qscan Group CEO
Phone: 07 3357 0975
Paul Newfield, Head of Australia & New Zealand, Morrison & Co
Phone: 02 8098 7500
You can make your report by email, telephone or in person. Alternatively, you may make a complaint in writing by downloading the Whistleblower Form on the intranet, completing the form and sending it in anonymously to the above contacts. You must make a disclosure directly to one of the above eligible recipients to be able to qualify for protection as a whistleblower under the Corporations Act (or the Taxation Administration Act, where relevant). Alternatively, you may use an external reporting process as noted below:
Qscan Group has contracted Your Call Whistleblowing Solutions (“Your Call”) to receive and manage your report with impartiality and confidentially.
This option allows you to:
The Your Call reporting options include:
Online reports can be made via the website address listed above. You will be required to enter Qscan Group unique identifier code: QSCAN
Your Call remains the intermediary at all times, receiving and forwarding communication between all parties. The Qscan Group Officers who will have access to your reports include:
Your Call can circumvent any of the above Officers upon your request.
You be able to securely upload any relevant documentation and/or material relevant to your disclosure.
After making a disclosure, you 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 Qscan Group.
Your Call remains the intermediary at all times, 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 you cannot access the Message Board, you can contact Your Call via phone (above) for verbal updates.
National Relay Service
If you are deaf, or have a hearing or speech impairment, you can contact Your Call online or through the National Relay Service. Simply choose your contact method at www.relayservice.gov.au and request Your Call’s hotline 1300 790 228.
Other external mechanisms:
A protected disclosure under the Corporations Act may also be made externally to one of the following:
A report under the Taxation Administration Act may also be made externally to the Commissioner for Taxation or a registered tax agent or BAS agent who provides tax agent services to the Group.
For emergency and public Interest disclosures, you may also report a disclosable matter to journalists and members of the Commonwealth, state or territory parliaments (parliamentarians).
You should read the Corporations Act and speak with Your Call, or an independent legal advisor to ensure you understand the criteria for making an emergency or public interest disclosure.
You can choose to remain anonymous while making a disclosure, over the course of the investigation and after the investigation is finalised. You can refuse to answer questions that you feel could reveal your identity at any time, including during follow-up conversations. If you wish to remain anonymous, it is recommended you maintain ongoing communication with Qscan (or Your Call), so that Qscan (or Your Call) can ask follow-up questions or provide feedback to you.
If you do not provide your name, any investigation will be conducted as best as possible under the circumstances however, an investigation may not be possible unless sufficient information is provided, and it may make it difficult to offer you the same level of practical support if Qscan (or Your Call) does not know your identity.
If you do provide your name, it will only be disclosed with your consent, or in exceptional circumstances where the disclosure is allowed or required by law (e.g. in dealings with a regulator or Federal Police). If you have concerns about this, you can discuss this with the whistleblower protection officer or Eligible Recipient [disclosure officer] or Your Call.
While making a report does not guarantee a formal investigation, all reports will be properly assessed and considered by Qscan and a decision made as to whether they should be investigated. If an investigation is undertaken, all workers must cooperate fully with any investigation. Investigators will be independent from any person to whom the report relates.
Qscan will treat the person to whom the report relates fairly, and any findings will be made on reliable evidence. When appropriate, a person being investigated will be provided with details of the report that involves them (to the extent permitted by law) and given an opportunity to respond. However, should patient care or worker safety be compromised, the person against whom allegations have been made may be suspended from duty pending investigation.
In addition, Qscan may appoint a Designated Protection Officer to support and help protect the person making a report of improper conduct. A Designated Protection Officer will be the reporter’s point of contact. They can arrange additional support for the reporter where needed and can escalate any concerns the reporter has with how their report is being dealt with. Qscan can only appoint a Designated Protection Officer where a person making a report has agreed to share their identity with the Designated Protection Officer.
|Group||Qscan Group and its wholly owned subsidiaries nationally.|
|Improper Conduct||Any suspected or actual misconduct or improper state of affairs or circumstances in relation to the group. Examples of improper conduct include:|
• breaches of laws or regulations
• ill-treatment of a patient
• a breach of Qscan’s policies including the Qscan Code of Conduct and global and domestic Anti-Bribery and Corruption policies
• dishonest or unethical behaviour
• acting on a conflict of interest, for example showing undue favour over a contractual matter or to an applicant for employment where the person is a family member or a friend
• conduct endangering health and safety, or causing actual or likely damage to the environment
• financial fraud or mismanagement
• victimisation or harassment
• conduct that represents a danger to the public or financial system
• deliberate concealment of any of the above
Improper conduct does not generally cover personal work-related grievances. Attachment 1 sets out examples where personal work-related grievances may qualify for legal protections.
|Personal work-related grievances||Grievances relating to an individual’s employment that have implications for the individual personally (e.g. disagreements between two employees or a promotion outcome decision). Generally, personal work-related grievances are more effectively addressed by contacting your relevant manager or Human Resources and they are generally not considered “protected disclosures.”|
6.0 Related Policies, Procedures & Guidelines
Attachment 1 – Protections provided by Australian Law
1. Legislative protections
You are encouraged to report improper conduct to the Recipients outlined in the Policy and you will be protected accordingly and appropriately.
The Corporations Act (Part 9.4AAA—Protection for Whistleblowers) also gives special protection to people who report improper conduct in other cases, so long as certain conditions are satisfied.
2. Protected disclosures
Certain information that is disclosed to certain people or organisations is protected by law. Examples include:
2.1 Information reported or disclosed
2.2 Recipient of disclosed information
The law also protects certain disclosures made in “emergency” and “public interest” situations, in which case disclosures can be made to additional recipients. Please contact Qscan’s Human Resource Manager if you would like more information about emergency and public interest disclosures.
3. Protected disclosures
Legal protection for disclosures about solely personal employment related matters are only available under the law in limited circumstances. A disclosure of a personal work-related grievance will be protected if, in summary:
4. Specific protections under the law
The protections given by the Corporations Act when the conditions are met include:
The law also states that if a reporter makes a protected disclosure: