1. Purpose
This policy sets out how Warrina Homes Incorporated (Warrina Homes) manages whistleblower disclosures in accordance with the Aged Care Act 2024 (Cth) (the Act) and the Aged Care Rules 2025, which mandate that providers operate a full whistleblower system, not merely a policy. The Act expands disclosure rights, strengthens protections, and embeds a rights-based approach to safety, transparency, and governance.
We are committed to supporting anyone who makes a whistleblower disclosure by:
- Protecting the identity of the whistleblower, where possible.
- Ensuring that no whistleblower, or their colleagues or relatives, suffers any form of detriment, including dismissal, demotion, intimidation, retaliation, harassment, or victimisation.
This Policy outlines the reporting process and provides support for individuals who wish to raise serious concerns or disclose wrongdoing.
2. Scope
This policy applies to all:
- The organisation
- Employees
- Contractors
- Volunteers
- Responsible persons (Board Members)
- Residents, families, carers, advocates
- Any other person allowed to make disclosures under the Act (including external parties)
3. Definitions
- Whistleblower: A person who reports a wrongdoing under this Policy.
- Wrongdoing: Any unethical, illegal, or improper conduct, including but not limited to:
- Abuse, neglect, or unsafe care
- Exploitation or rights violations (contrary to the Statement of Rights established by the Act)
- Misuse of funds or fraud
- Breaches of duty by responsible persons
- Failure to meet regulatory reporting obligations
- Attempts to hide or cover up non-compliance
- Protected Disclosure: A disclosure made in accordance with applicable legislation that attracts legal protection.
- Whistleblower Disclosure: A specific form of disclosure recognised under law that is eligible for legal protections and relates to actual or suspected wrongdoing within Warrina Homes.
- Whistleblower Protection Officers: A Whistleblower Officer is a designated individual responsible for receiving and managing whistleblower disclosures, ensuring confidentiality, and facilitating appropriate assessment and investigation of reported concerns.
4. Policy Guidelines
a. Who Can Make a Disclosure
Any person, including employees, residents, family members, contractors, volunteers, responsible persons, carers, advocates or any other person allowed to make disclosures under the Act may make a whistleblower disclosure.
b. When to Make a Disclosure
A disclosure should be made when the individual has reasonable grounds to suspect that Warrina Homes or any person has contravened the Act or engaged in wrongdoing.
c. Distinguishing Complaints from Disclosures
A complaint involves general dissatisfaction with services and is handled through Warrina Homes’ Feedback and Complaints Management Process.
If you are unsure whether your concern qualifies as a whistleblower disclosure, please contact one of the Whistleblower Officers listed below for guidance.
d. Whistleblower Protections
Under the Act and other relevant legislation, whistleblowers receive:
- Immunity from civil, criminal, administrative, and contractual consequences (except for their own misconduct)
- Protection from dismissal, demotion, or discrimination in the workplace
- Protection from harassment, intimidation, or retaliation
- Protection from damage to reputation, career, or employment prospects
- Protection from breaches of confidentiality, except where disclosure is required by law
e. How to Make a Disclosure
You may raise your concern to any of the following Warrina Homes Whistleblower Officers:
Chief Executive Officer: Andrew Curle
Phone: 1300 424 332 | Email: andrew.curle@warrinahomes.com.au
Executive Manager, Governance & Compliance: Priyanka Padale
Phone: 1300 424 332 | Email: priyanka.padale@warrinahomes.com.au
You may also report directly to an external authority, such as:
- The Aged Care Quality and Safety Commission
- The Australian Securities and Investments Commission (ASIC)
- The Australian Taxation Office (ATO) (for taxation-related matters)
- Complaints Commissioner
- The System Governor (Secretary of the Department of Health, Disability and Ageing)
- Police
- Independent aged care advocates
f. Whistleblower Management Procedure
Warrina Homes will:
- Assess the disclosure to determine appropriate action and whether an investigation is required.
- Treat all disclosures seriously and take reasonable steps to protect the whistleblower’s identity. Where a whistleblower’s identity is known, assigning a Whistleblower Protection Officer to the case to monitor the workplace for signs of retaliation, harassment or victimisation and to intervene when necessary.
- Conduct investigations in accordance with principles of objectivity, confidentiality, procedural fairness, and natural justice.
- Comply with all relevant legal obligations under the Act and, where applicable, the Corporations Act 2001 (Cth).
g. Training
All Employees and Responsible Persons receive training on recognising and appropriately handling disclosures, integrated into the annual training plan.
h. Anonymous Disclosures
Disclosures may be made anonymously. However, providing contact details may assist with protecting the Whistleblower’s wellbeing and allow for more effective investigation and communication. Lack of contact details may limit the Whistleblower Officers ability to fully investigate the matter.
i. False or Malicious Reports
Do not use these whistleblowing procedures to report minor matters that do not constitute wrongdoing as defined in this Policy. Intentional false disclosures may result in disciplinary action. This is consistent with the rights-based and no-retaliation framework in the Act.
j. Information Required for Investigation
To enable an effective response, please include as much detail as possible, such as:
- Description of the incident or conduct
- Names, positions, and roles of individuals involved
- Relevant dates, times, and locations
- Possible witnesses
- Supporting evidence or documents
k. Feedback to the Whistleblower
Where the whistleblower’s identity or communication channel is known, Warrina Homes will provide appropriate feedback throughout the process without compromising confidentiality. The frequency and timeframes for providing feedback will vary according to the nature of the disclosure and the investigation. Feedback may include:
- Confirmation that the disclosure has been received and is being reviewed
- Updates on progress, where possible
- Notification of the outcome where appropriate:
- If the matter is substantiated, details of remedial actions taken or planned
- If not substantiated, confirmation that no further action will be taken unless additional evidence emerges
l. Alignment with the Strengthened Aged Care Quality Standards
This Policy aligns with the requirements under the Aged Care Quality Standards as below:
- Standard 2 (Organisational Governance)
Supports safe, transparent incident, feedback, and whistleblower systems.
Ensures residents can raise issues “without fear”. - Statement of Rights
Guarantees dignity, privacy, autonomy, safety, and the right to speak up.
5. Review Cycle
This policy will be:
- Reviewed annually (mandatory under the Aged Care Rules 2025)
- Updated following legislative changes or emerging risks.
6. References
