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Whistleblowing Policy

  1. BACKGROUND

    1. The Aspen APAC Group, comprising Apple SG BidCo Pte Ltd and Aspen Asia Pacific Pty Ltd and each of their subsidiaries, including Aspen Pharmacare Australia Pty Ltd (including Aspen New Zealand), Aspen Pharma Pty Ltd, Aspen Pharmacare Asia Limited (including the Representative Office in Vietnam), Aspen Philippines Inc, Aspen Healthcare Taiwan Ltd, Aspen Medical Products Malaysia Sdn Bhd, and Aspen Vietnam, is committed to conducting its business according to the highest ethical standards and in accordance with applicable laws.
    2. In line with this commitment, and the Aspen APAC Group’s commitment to open communication, this Policy aims to provide an avenue for employees, customers, suppliers and other stakeholders, on an anonymous basis if preferred, to raise concerns regarding improper conduct within Aspen, without fear of retaliation.
    3. This policy does not form part of any employment contract and may be amended at Aspen’s discretion.

  2. WHO CAN RAISE CONCERNS OR DISCLOSE IMPROPER CONDUCT

    The reporting mechanisms set out in this Policy are available to all employees, suppliers and customers of the Aspen APAC Group, or other eligible stakeholders as prescribed under applicable laws.

  3. DISCLOSURES WHICH QUALIFY FOR PROTECTION

    1. A disclosure of information is protected under this Policy if the person has reasonable grounds to suspect that the information concerns or indicates improper conduct in relation to an Aspen APAC Group entity, employee or officer, and the disclosure is made in accordance with this Policy (“Protected Disclosure”).
    2. Improper conduct is conduct which is contrary to our values and Code of Conduct (“Improper Conduct”), including, as examples:
      1. criminal offences, including fraud, bribery, corruption, money laundering, terrorist financing;
      2. a violation of human rights;
      3. labour practices that constitute modern slavery, including unlawful child labour;
      4. breach of legal obligations or applicable industry codes;
      5. breaches of Aspen APAC Group policies and procedures that underpin the Aspen APAC Group Code of Conduct;
      6. conflicts of interest;
      7. conduct that presents a danger to employees, the communities in which we operate, or to the environment;
      8. theft or improper use of company assets / resources;
      9. improper:
        1. accounting practices,
        2. internal accounting controls, financial reporting; or
        3. auditing matter; and
      10. unlawful disclosure or misappropriation of Aspen APAC Group intellectual property or confidential information.
    3. This Policy is not intended as a process to resolve personal work-related grievances, nor as an appeal process to reconsider any matter that has already been dealt with through the applicable grievance or disciplinary process. Examples include an interpersonal conflict between two employees, or a decision relating to an employee, such as a transfer, promotion, performance evaluation, salary increase, or disciplinary action.

  4. DUTIES OF EMPLOYEES IN RELATION TO IMPROPER CONDUCT

    Employees of Aspen APAC Group companies who become aware of improper conduct are expected to report the matter by making a Protected Disclosure under this Policy.

  5. HOW TO GO ABOUT REPORTING IMPROPER CONDUCT

    1. Internal Reporting
      1. A Protected Disclosure can be raised through any of the following internal channels (the “Internal Reporting Outlets”):
        1. an immediate supervisor or line manager;
        2. the senior executive responsible for your business or area,
        3. the relevant Ethics & Compliance Officer, or supporting Legal Counsel;
        4. the Group Executives Legal, Human Resources or Ethics & Compliance; or
        5. if you believe that the matter cannot be appropriately dealt with through the channels recorded in paragraphs 5.1.1.1. to 5.1.1.4. above, or if you are an external party wishing to raise a concern, you can make use of the Speak Up service, as described in paragraph 6 below.
      2. Irrespective of the Internal Reporting Outlet used, to enable us to properly investigate your Protected Disclosure, please provide as much detailed information as possible, including:
        1. a description of the suspicion, concern or alleged improper conduct;
        2. the names of the implicated persons, their line manager and the names of any witnesses or other parties who may be aware of the matter; and
        3. any emails or documents that may support the allegation.
    2. External And Public Reporting
      1. In considering whether to take a concern outside of the Aspen APAC Group, you should consider whether reporting the concern externally, without first giving us the opportunity to look into the matter, is a reasonable course of action. It would not normally be appropriate to disclose your concerns externally unless you have first followed the procedures in this Policy.
      2. If however:
        1. you have reasonable grounds to believe that, by using one of the Internal Reporting Outlets, the investigation into the alleged improper conduct could be jeopardised; or
        2. We have failed to respond to your Protected Disclosure within the maximum period allowed under applicable law;
        3. the Internal Reporting Outlets have been otherwise exhausted,then you can, subject to applicable law, report your concern externally to the relevant competent national authority.
      3. You can only make a public disclosure regarding your concern (for example to the press or via social media) as permitted under applicable laws.

  6. SPEAK UP SERVICE

    1. Speak Up is a confidential reporting service operated by an independent third party contracted to us (the “Service Provider”), and is available 24 hours a day, 365 days a year. The Service Provider can accommodate Protected Disclosures in English and in local language in Hong Kong, Taiwan, Malaysia and Philippines and can be contacted directly from those locations in addition to Singapore, Australia and New Zealand.
    2. There are two options for submitting a Protected Disclosure via Speak Up:
      1. Online: https://AspenAPAC.dws.deloitte.com.au
      2. By phone, using the appropriate FreeCall telephone numbers (or if none are appropriate, the tolled number) listed on the Aspen Pharmacare Australia website: https://www.aspenpharma.com.au.

  7. WHAT HAPPENS TO A PROTECTED DISCLOSURE

    1. If you make a Protected Disclosure using one of the Internal Reporting Outlets described in paragraphs 5.1.1.1. to 5.1.1.4. above: 
      1. Your report will follow the in-country procedure for reporting and investigation, as directed by local management, with escalation to where required by relevant Aspen APAC Group policies, or where otherwise appropriate in the circumstances;
      2. We will acknowledge receipt of and provide feedback in respect of your Protected Disclosure within the timelines prescribed under applicable laws; and
      3. We will designate an impartial person or department for following up on the reports, who will maintain communication with you and, where necessary, ask for further information from and provide feedback to you.
    2. The following steps will be followed if you make a Protected Disclosure using the Internal Reporting Outlet described in paragraph 5.1.1.5 (Speak Up):
      1. Step 1: If the Protected Disclosure is submitted via a live telephone operator or the Speak Up website, a reference number will be provided which can be used to request feedback on actions taken. If a voice recording service is used, feedback will only be possible if contact details are provided as part of the message submitted.
      2. Step 2: The Service Provider will discuss your Protected Disclosure, in order to obtain as much information as possible.
      3. Step 3: If you elect to make a Protected Disclosure with partial anonymity, the Service Provider will sanitise your report, by removing your name and any contact details that may enable your identity to be disclosed.
      4. Step 4: The Protected Disclosure will be passed on by the Service Provider to the relevant Ethics & Compliance Officer. We will, via the Service Provider, acknowledge receipt of your Protected Disclosure and provide feedback within the timelines prescribed under applicable laws. You may also request feedback by phone, email or online via the website, by quoting the case reference number.
    3. Irrespective of the Internal Reporting Outlet used, the alleged improper conduct will be investigated. The investigation team may comprise of internal or external parties, or a combination of both, depending on the nature and complexity of the matter reported.
    4. We reserve the right to not investigate any allegation where insufficient information has been provided, or, in the discretion of the relevant Ethics & Compliance Officer, does not constitute Improper Conduct, or is not based on reasonable grounds.
    5. We reserve the right to request, via the relevant Reporting Outlet, further specific information or substantiation in respect of the alleged Improper Conduct, prior to commencing our investigation.

  8. WHISTLEBLOWER ANONYMITY

    A person making a Protected Disclosure may advise that they wish to remain anonymous, or place restrictions on who knows their identity. Aspen and the Service Provider will comply with such request and we will use our best endeavours to investigate an anonymous disclosure. There may, however, be limitations in investigating the matter where the whistleblower chooses to remain anonymous.

  9. CONFIDENTIALITY

    1. All Protected Disclosures, and the whistleblower’s identity (where this is disclosed or becomes known), are treated confidentially and will only be shared with a limited group of people on a strict need-to-know basis. Information will only be disclosed outside this small group if we are required to do so by law or an important public interest is at stake, such as public safety.

    2. Where we are required by law to inform the person who is the subject of a Protected Disclosure that a complaint has been filed against them, the whistleblower’s identity will not be disclosed and such notification will be deferred until the investigation has run its course. This is to protect you, the whistleblower, as well as to protect the integrity of the whistleblowing process.
    3. In some cases, however, confidentiality cannot be guaranteed as the very fact of the investigation may serve to reveal the source of the information, the statement of the person raising the concern may be needed as part of evidence against the perpetrator, or legal proceedings at a later stage may require the individual to appear as a witness.
    4. Disciplinary action will be taken against any employee who makes an unauthorised disclosure of the identity of a person who makes a Protected Disclosure under this Policy, or of information that will likely lead to the identification of such person.

  10. Whistleblower protection

    1. The protection of whistleblowers is fundamental to the success of the Aspen APAC Group whistleblower process. It is also a right afforded by law in many jurisdictions in which we operate. See also the Australian Specific Supplement at the end of this Policy which sets out special protections under Australian Corporations and Taxation Acts. No employee who makes a disclosure based on reasonable grounds, and in accordance with this Policy will, as a consequence of making a Protected Disclosure, suffer retaliation, including being:
      1. subjected to any disciplinary action;
      2. dismissed, suspended, demoted, harassed or intimidated;
      3. transferred against his or her will;
      4. refused transfer or promotion;
      5. subjected to a term or condition of employment or retirement which is altered or kept altered to his or her detriment;
      6. refused a reference or provided with an adverse reference;
      7. denied appointment to any employment, profession or office;
      8. threatened with any of the above; or
      9. otherwise adversely affected in his or her employment, including employment opportunities and work security.
    2. The equivalent protection, where relevant, is also extended to any external organisation represented by the whistleblower, such as a supplier.
    3. The above protection is not afforded to an individual who has opted to blow the whistle on his or her own improper conduct.
    4. Where a whistleblower reports false information, knowing it to be false, the above protection will not be available to them, and if they are an employee they will face disciplinary action up to and including dismissal.
    5. We view retaliation against a whistleblower in a very serious light. Accordingly an employee who retaliates against a whistleblower in violation of this Policy will be subject to disciplinary action, up to and including dismissal.
    6. If a whistleblower feels they have suffered retaliation as a result of making a Protected Disclosure, they should immediately report the matter to the Group Executive: Legal & Compliance as follows:
      Speak Up@aspenpharmacare.com.au

  11. PERSONAL INFORMATION

    1. Aspen APAC Group companies are responsible for personal information processed in accordance with this Policy.
    2. Personal information is disclosed as set out in paragraph 5 above and to the Aspen APAC Group company that needs access to the information in order to investigate the alleged improper conduct and take appropriate action.
    3. For detailed information on how we use and disclose personal information, the protections we apply, the legal bases for our use of the personal information and your data protection rights, please refer to Annexure A.

  12. FAIR TREATMENT OF INDIVIDUALS MENTIONED IN PROTECTED DISCLOSURES

    1. Where the allegation of improper conduct has not been substantiated, the fact the investigation has been carried out, the results of the investigation, and the identity of any person who is the subject of the Protected Disclosure will remain confidential, unless the subject requests otherwise.
    2. Subject to applicable laws, and paragraph 9.2, an employee who is the subject of a Protected Disclosure has the right to:
      1. be informed as to the substance of the allegations;
      2. be given a reasonable opportunity to put their case (either orally or in writing) to our Group Executives Legal, Human Resources or Ethics & Compliance; and
      3. be informed of the findings in respect of the Protected Disclosure.

  13. IMPROPER USE OF THIS POLICY

    1. This Policy should not be used for settling personal disputes or reporting complaints relating to an employee’s own personal work-related circumstances, such as the way he/she has been treated at work. In such cases, the applicable grievance or other relevant procedure should be followed.
    2. Any person who knowingly or deliberately submits a malicious report may be subject to penalties under applicable laws. In addition, where the person is an employee of an Aspen APAC Group company, disciplinary action may be taken, up to and including termination of the employment relationship.

ANNEXURE A: PRIVACY NOTICE

Capitalised terms have the meaning ascribed to them in the Whistleblowing Policy to which this Annexure A is appended unless otherwise defined in this Annexure A.

  1. INTRODUCTION

    1. We receive reports regarding alleged improper conduct in terms of the Aspen APAC Group Whistleblowing Policy (Policy).
    2. The Policy makes provision for various Internal Reporting Outlets, including the Speak Up service managed by the Service Provider.
    3. This Privacy Notice applies to the personal information or personal data (“personal data”) of any whistleblower (“you” or “your”) collected, used, disclosed, held or otherwise processed by us in connection with a Protected Disclosure under the Policy, including our receipt, process and investigation of the same. If you submit a Protected Disclosure via any of the Internal Reporting Outlets, we will process your personal data in accordance with this Privacy Notice.
    4. To the extent relevant under applicable laws, the “data controller” of any personal data that may be processed in connection with this Privacy Notice is the Aspen APAC Group entity employing the whistleblower and / or Aspen Pharmacare Australia Pty Ltd.

  2. WHAT DATA DO WE PROCESS?

    1. When you make a Protected Disclosure through any of the Internal Reporting Outlets, the recipient or the Service Provider (as the case may be) will collect and process your personal data which may include your name, surname, email address, contact number and, if you are an employee of an Aspen APAC Group company, the name of your employer, your employee number, business unit and location, and any other personal data that you provide or which may be relevant to, or required for, the Protected Disclosure. The content of your Protected Disclosure will also be collected and processed which may include your personal data, such as details of the relevant incident or event you have witnessed or wish to report, and details of any personal opinion or expressions you wish to make in connection with the incident.
    2. If a Protected Disclosure is made about your alleged conduct or involvement in alleged improper conduct, the recipient, or the Service Provider (as the case may be) will in general collect your name, surname, alias or nickname, gender, and (where applicable) employee number, title, company, division, and contact information. Information will also be collected about the allegation that is reported, including the nature of the allegation.
    3. Even if your Protected Disclosure is made anonymously or you place restrictions on who knows your identity, your personal data may nonetheless be incidentally generated, inferred or otherwise collected and processed in connection with your Protection Disclosure. Note that if you choose to remain anonymous in connection with a Protected Disclosure or place restrictions on who knows your identity, we may be unable to effectively process and investigate the alleged improper conduct, provide you with information on the outcome of the Protected Disclosure, afford you the protections available under the Policy and applicable law, or otherwise interact with you.
    4. Some of this personal data is collected as required or authorised by certain laws governing illegal, unethical or corrupt conduct, including the Corporations Act 2001 and the Taxation Administration Act 1953.
    5. If you do not provide personal data which We or the Service Recipient request, this may limit our ability to investigate your Protected Disclosure.
    6. Notwithstanding the basis on which the Protected Disclosure is made, all personal data provided via any of the Internal Reporting Outlets will be managed confidentially. Where the Protected Disclosure is submitted via the Speak Up service, the Service Provider will not disclose your personal data to Aspen without your consent.

  3. HOW DOES THE COMPANY COLLECT DATA?

    We collect personal data of the whistleblower and / or the individual(s) referred to in the Protected Disclosure from the whistleblower or the Service Provider (subject to the whistleblower’s prior consent), through the relevant Internal Reporting Outlet used to make the relevant Protected Disclosure. Furthermore, additional personal data may be generated and processed through the course of any investigation into the alleged improper conduct.

  4. WHAT ARE THE PURPOSES FOR WHICH DATA IS PROCESSED AND WHAT IS OUR LEGAL BASIS FOR CARRYING OUT THE PROCESSING?

    1. Where we process your personal data in connection with a Protected Disclosure, the overarching purpose is to facilitate the raising of concerns about improper conduct, the investigation of those concerns, and (where the concerns are found to be valid) taking appropriate action to address them, and prevent similar concerns from arising in the future.
    2. This may involve processing your personal data to:
      1. receive, discuss and (where applicable) sanitise the Protected Disclosure;
      2. request additional information to substantiate the Protected Disclosure;
      3. collate information received in a Protected Disclosure and make that information available to designated persons for investigation;
      4. investigate the alleged improper conduct; and
      5. provide feedback to you, and make recommendations to Aspen companies.
    3. Some data protection laws require a valid legal ground to process personal data. We process personal data where necessary to:
      1. comply with our legal or regulatory obligations (for example, laws relating to the combating of bribery, and other laws that require us to operate whistleblowing hotlines), participate in legal and regulatory processes (such as investigations and disputes), and exercise our rights;
      2. meet our legitimate interests; or
      3. protect the vital interests of the relevant individual or of another natural person,or for such other purposes notified to you for which you have given your consent against or which are otherwise permitted or required by applicable law.
    4. The legitimate interests referred to above include our interests in addressing conduct which is contrary to our Code of Conduct, acting ethically and responsibly as a business, complying with laws, and protecting the environment and the health and safety of our employees.

  5. RETENTION OF PERSONAL DATA

    1. We endeavour to keep your personal data accurate, complete, up-to-date, relevant and not misleading.
    2. We will retain your personal data for only as we need to, including to comply with applicable laws and participate in legal and regulatory processes (such as investigations and disputes), and for other legitimate business reasons.
    3. We will take reasonable steps to ensure the Service Provider (where applicable) retains your personal data for only as long as is appropriate to investigate the Protected Disclosure and, where relevant, to complete actions relating to the outcome of any such investigation, in both cases in accordance with applicable law and to comply with legal, regulatory or internal policy requirements.
    4. We will take reasonable steps to protect your personal data. In general, reports in connection with Protected Disclosures are retained in a secure and limited-access database in order for us to retain an ability to respond to future legal claims in respect of associated actions.

  6. DISCLOSURES OF PERSONAL DATA

    1. We may disclose your personal data as appropriate to:
      1. the Aspen Group Executives Legal, Human Resources or Ethics & Compliance and our investigations team;
      2. the Service Provider, who receives the information submitted as part of a report, and receives feedback from Aspen APAC Group companies on the report;
      3. internal and external advisors, which may include forensic companies, who assist with the investigation;
      4. Aspen APAC Group companies which have a need to access information in a report, for example, if the outcome of the investigation recommends action against an employee, the investigation report will be provided to the relevant employer, including the line manager and relevant member of the HR team;
      5. third parties who provide services to us and the Service Provider, such as IT systems providers or hosting providers; and
      6. courts or tribunals, government and other public bodies, law enforcement agents and litigants where laws require us to make a disclosure, such as where a report is found to be false, unsubstantiated and made maliciously, and the accused person seeks that disclosure as part of an action for libel or defamation.
    2. We expect any third parties to process any personal data disclosed to them in accordance with applicable law, including with respect to data confidentiality and security. In particular, our contract with the Service Provider requires it to protect personal data, including withholding whistleblowers’ identities where an anonymous Protected Disclosure is made or in instances where the whistleblower has not provided consent to disclose personal data.
    3. Where these third parties act as a “data processor” they carry out their tasks on our behalf and upon our instructions for the above mentioned purposes. In this case, your personal data will only be disclosed to these parties to the extent necessary to provide the required services.
    4. In addition, we may share personal data with regulators and national authorities in order to comply with a legal obligation to which we are subject. This is, for example, the case in the framework of imminent or pending legal proceedings or a statutory audit.

  7. INTERNATIONAL TRANSFER OF PERSONAL DATA

    1. Some personal data may be transferred to, or otherwise accessed or accessible from, countries other than the one in which the matter was reported, including Australia, New Zealand, Singapore, Taiwan, Malaysia, Philippines, Hong Kong and Vietnam.
    2. For example, the relevant Ethics & Compliance Officer and Group Executives Legal, Human Resources or Ethics & Compliance to whom Protected Disclosures are notified are based in Singapore and / or Australia. As a result, personal data may be transferred out of the country in which the matter was reported, to Australia and / or Singapore.
    3. Any transfer of personal data intra-Group is governed by our Intra-Group Data Transfer Agreement.

  8. YOUR RIGHTS

    You can obtain a copy of our privacy policy at https://www.aspenpharma.com.au/privacy/ or by contacting us (see section ‘Contact Us’ below). Our privacy policy contains further information on the handling of your personal data and your privacy rights, including your right to withdraw your consent, make privacy complaints or to request access to or correct of your personal data.

  9. Contact us

    You may contact our Privacy Officer at:
    privacy@aspenpharmacare.com.au

  10. Notice of changes

We may change or update this Privacy Notice at any time, in accordance with applicable laws. We encourage you to check this Privacy Notice from time to time for updates.

Last updated: June 2026

 

AUSTRALIAN SPECIFIC SUPPLEMENT
TO ASPEN APAC GROUP WHISTLEBLOWING POLICY

SPECIAL PROTECTIONS UNDER THE AUSTRALIAN CORPORATIONS ACT 2001 AND TAXATION ADMINISTRATION ACT 1953

 

Capitalised terms have the meaning ascribed to them in the Whistleblowing Policy to which this is a supplement.

References to Aspen in this Supplement are references to Aspen Pharma Pty Ltd,
Aspen Pharmacare Australia Pty Ltd, Aspen Asia Pacific Pty Ltd and ENT Technologies Pty Ltd.

The Corporations Act and Taxation Administration Act give special protection to Protected Disclosures about misconduct, or an improper state of affairs or circumstances (but not solely personal work-related grievances) in relation to Aspen, where the following conditions are satisfied:

  1. The whistleblower is or has been:
    1. an officer or employee of Aspen;
    2. an individual, or employee of a person, who supplies goods or services to Aspen (paid or unpaid);
    3. an associate of Aspen; or
    4. a relative, dependent or dependent of the spouse of any individual in (a) to (c).
  2. The disclosure is made to: 
    1. an officer or senior manager of Aspen;
    2. an auditor, or a member of an audit team conducting an audit of Aspen;
    3. an actuary of Aspen;
    4. a person authorised by Aspen to receive disclosures that may qualify for protection;
    5. a legal practitioner for the purpose of obtaining legal advice or legal representation in      relation to the operation of the whistleblower provisions in the Corporations Act and Taxation Administration Act;
    6. a member of the Australian Federal Police;
    7. ASIC, APRA or a prescribed Commonwealth authority;(for public interest disclosures)
    8. a journalist or member of Parliament (Federal, State or Territory) if the whistleblower:
      1. does not have reasonable grounds to believe action is being taken to address the matter that they disclosed to any of 2(a)-(g) (the previous disclosure); 

        and

      2. has reasonable grounds to believe further disclosure is in the public interest;and
      3. has, at least 90 days after the previous disclosure was made, given written notice to the body to whom the previous disclosure was made that they intend to make a public interest disclosure;(for emergency disclosures)

         

    9. a journalist or member of Parliament (Federal, State or Territory) if the whistleblower:
          • has disclosed the matter to any of 2(a)-(g) (the previous disclosure); and
          • has reasonable grounds to believe that the disclosure concerns a substantial and imminent danger to the health or safety of one or more persons or to the natural environment; and
          • has given written notice to the body to whom the previous disclosure was made that they intend to make an emergency disclosure;

      (additionally, for disclosures under the Taxation Administration Act only, if the discloser considers the information may assist the recipient to perform their functions or duties in relation to the tax affairs of Aspen or under a taxation law in relation to Aspen)

    10. any employee or officer of Aspen who has functions or duties that relate to the tax affairs of Aspen;
    11. the Australian Commissioner of Taxation; or
    12. a registered tax agent or BAS agent who provides tax agent services or BAS services to Aspen.

Special Whistleblower Protections

The following protections are provided by the Corporations Act and Taxation Administration Act when the above conditions 1 and 2 are satisfied:

  1. the whistleblower cannot be subject to any civil, criminal or administrative liability (including disciplinary action) for the making the disclosure;
  2. no contractual or other remedy can be enforced, and no contractual or other right can be exercised, against the whistleblower for making the disclosure;
  3. the information disclosed to ASIC, APRA, the Commissioner of Taxation and in public interest or emergency disclosures is not admissible against the whistleblower in criminal proceedings or proceedings for the imposition of a penalty, other than proceedings in respect of the falsity of the information;
  4. the whistleblower has qualified privilege in respect of the disclosure for the purposes of defamation law;
  5. a contract to which the whistleblower is a party cannot be terminated on the basis that the disclosure constitutes a breach of the contract;
  6. it is an offence for a person to cause or threaten to cause detriment to a whistleblower or another person because they believe or suspect that a disclosure qualifying for protection under the Corporations Act or the Taxation Administration Act has been or may be made;
  7. a court may require a person to compensate a whistleblower or any another person for loss, damage or injury suffered as a result of detrimental conduct experienced in connection with the qualifying disclosure;
  8. a whistleblower’s identity must be kept confidential unless one of the following exceptions applies:
    • the discloser consents to the disclosure of their identity;
    • it is considered necessary for their identity to be disclosed to a Court or tribunal;
    • disclosure of details that might reveal the discloser’s identity is reasonably necessary for the purposes of investigating the matter and all reasonable steps have been taken to reduce the risk of the disclosure being identified;
    • the disclosure is made to ASIC, APRA, the AFP, the Commissioner of Taxation or a legal practitioner for the purpose of obtaining legal advice or legal representation in relation to the whistleblower regime in the Act.

Aspen will investigate Protected Disclosures made to it that qualify for protection under the Corporations Act or the Taxation Administration Act, and will ensure fair treatment of Aspen employees mentioned in such disclosures, as set out in the Aspen Group Whistleblowing Policy to which this is a supplement.

Note: Disclosure via Speak Up will not provide the special protections set out above. 

You should refer to the applicable laws and/or obtain legal advice if you wish to be able to rely on the special protections outlined in this Supplement to the Aspen APAC Group Whistleblowing Policy.

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