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Whistleblower Policy and Procedures


Calvary Christian Church is multi-campus Church committed to high standards of behaviour amongst team members according to faith in Biblical principles and legislation governed by State and Commonwealth Law.  As an employer of staff, manager of volunteers, contractor and training provider (Calvary Leadership College and work experience students), Calvary Christian Church is committed to promoting a positive culture of high ethical behaviour and therefore has policy and practice in place to detect and prevent illegal, unethical or undesirable conduct.

There are a number of policies, procedures and practices in place where team can be guided by what constitutes ethical conduct and how they can report a wrong doing in key areas:

  • Calvary Christian Church Complaint Resolution Procedure
  • Calvary Christian Church Workplace Bullying Policy
  • Calvary Christian Church Sexual Harassment Policy
  • Calvary Christian Church Anti-Discrimination Policy
  • Calvary Christian Church Workplace Health and Safety Policy
  • Calvary Christian Church Employee Code of Conduct
  • Calvary Christian Church Volunteer Code of Conduct
  • Calvary Christian Church Work Placement Code of Conduct
  • Australian Christian Churches Ministerial Code of Conduct
  • Australian Christian Churches Child Protection Policy
  • Australian Christian Churches Safer Churches Policy
  • RiskEZI – Calvary Christian Church’s online safety management system which includes Incident Reporting and review
  • Annual preparation of financial statements including an annual audit by an external auditor
  • Annual Staff and Volunteer Inductions
  • Regular group team meetings (usually weekly) lead by the Senior Pastor/local Campus Pastor where ethics and conduct are a regular discussion
  • Regular Campus Pastor meetings (usually every 2 months) lead by the Senior Pastor where ethics and conduct are a regular discussion
  • Regular supervisory one-on-one meetings lead by the Senior Pastor/local Campus Pastor where ethics and conduct are a regular discussion
  • Ministry Area Handbooks (eg Youth and Kids Ministries) that detail expected behaviours and interactions towards the ministry target group
  • Regular group training for ministry areas lead by the ministry Director
  • A local open-door policy to the Campus Pastor
  • An open-door policy to the Business Manager/Privacy Officer
  • Escalation of issues to the Senior Pastor if there is an inadequate local response.

Calvary Christian Church acknowledges that there are situations which are beyond the scope of the above and meet the criteria of Regulation Guide 270 under the Corporations Act 2001 that require a response that protects the person who is bringing the disclosure.  In these instances, an individual may choose to take action as a Whistleblower and receive the protections associated with this action guaranteed under the Corporations Act.


The purpose of this Whistleblower Policy is to identify how a person can voluntarily disclose Misconduct (as defined in Section 5) or suspicions of Misconduct within the Church. This Policy ensures that this disclosure can be made anonymously, confidentially and without fear of repercussion. All people utilising this Policy will be treated fairly and with strict confidentiality.

This Policy defines the protections available to Whistleblowers under the Corporations Act (2001).

Reports regarding personal work-related complaints will not be afforded protections under this Policy and will be referred to existing appropriate policy documents for alternative resolution mechanisms (See Section 7).


This Policy applies to all staff, contractors, volunteers, students (Calvary Leadership College and work experience students), and Board Members of Calvary Christian Church entities (except for Calvary Christian College and Emerald OSCH).


Commonwealth Laws
Corporations Act 2001

Regulatory Guide 270:  Whistleblower Policies. November 2019. Australian Securities and Investments Commission.


For the purpose of this Policy:

“The Church” means Calvary Christian Church

“Misconduct” in this Policy includes conduct that:

  • Constitutes an offence against, or a contravention of, a provision of any of the following:
    • The Corporations Act 2001;
    • The Australian Securities and Investments Commission Act 2001;
    • The Banking Act 1959;
    • The Financial Sector (Collection of Data) Act 2001;
    • The Insurance Act 1973;
    • The Life Insurance Act 1995;
    • The National Consumer Credit Protection Act 2009;
    • The Superannuation Industry (Supervision) Act 1993;
  • Constitutes an offence against any other law of the Commonwealth that is punishable by imprisonment for a period of 12 months or more; or
  • Represents a danger to the public or the financial system; or
  • Is prescribed by regulations for the purposes of paragraph 1317AA(5) of the Corporations Act 2001.
  • Some examples of the Misconduct relevant to this Policy might be fraud, money laundering, and misappropriation of funds. It may also be engaging in detrimental conduct towards a person who has made or is making a disclosure.  A disclosable matter regarding Misconduct could also include information that indicates a significant risk to public safety or the stability of, or confidence in, the financial system even if it does not involve a breach of a particular law.
  • For noting is that disclosures that are not about ‘disclosable matters’ (as outlined above) do not qualify for protection under the Corporations Act.

“Whistleblowing” is the voluntary disclosure of Misconduct (as defined above) by a person who has witnessed instances of, or, holds suspicions regarding Misconduct (as defined above) within the Church.

“Whistleblower” is an officer, employee, contractor or volunteer of any entity within the Church who reports Misconduct (as defined above) in accordance with this Policy.

“False reporting” is knowingly bringing a report which is false, baseless or vexatious.  Such reports will be dismissed, and no further action will be taken on these types of reports under this Policy.


All officers, employees, contractors or volunteers of any entity within the Church will be made aware of this Policy and the pathways available to report instances of (or suspicions of) Misconduct.

This current version of this Policy will be available to all officers and employees through RiskEZI – Calvary’s online risk management system.  A copy will be given to any person upon request.


Nominated Whistleblower Protection Officers

The Church has nominated two Internal Whistleblower Protection Officers, to receive reports of Misconduct and protect the interests of the Whistleblower in terms of this Policy. The Church will seek to ensure that all officers, employees, contractors and volunteers are aware of the current nominated Whistleblower Protection Officer/s and mechanisms to contact them.

Where reporting within the Whistleblower’s normal reporting channels (ie. to their immediate leader or supervisor) is not desirable or appropriate, the Whistleblower may report instances of, or suspicions of, Misconduct to the Internal Whistleblower Protection Officers.

Internal Whistleblower Protection Officers: Fay Barker and Nathan Spicer

Email: [email protected];  [email protected]


Investigation procedures:

All reports of Misconduct made under this Policy will be assessed and investigated.

Upon receiving a report from a Whistleblower, the Whistleblower Protection Officer inform the Church’s Board Chair, the Senior Pastor, that a report of Misconduct has been received and will determine whether the disclosure is a matter of Misconduct to which this Policy applies, within 72 hours of receiving the report.

Where the Whistleblower Protection Officer determines that a report is trivial, vexatious or baseless, the Whistleblower Protection Officer will inform the Whistleblower of this assessment and no further action will be taken in relation to the report.

If it is determined that the report is a matter to which this Policy applies, the following investigation processes will apply:

  • The Whistleblower Protection Officer will appoint an investigator within 7 days of receiving the report. The investigation must not be conducted by a person who may be the subject of the investigation or has connections (actual or perceived) to the persons or issues under investigation. In making this appointment, the Whistleblower Protection Officer must consider whether the appointment of an external investigator is appropriate, having regard to the nature of the Misconduct alleged and the persons implicated in the allegations.
  • Investigations must be conducted in a fair and transparent manner, affording principles of natural justice to any persons implicated in a report of Misconduct and preserving the confidentiality (to the greatest extent possible) of the person.
  • Investigations regarding reports made under this Policy should be completed within 21 days of the appointment of an investigator. If for any reason an investigation cannot be completed within 21 days, the Whistleblower must be informed of the delay by the Whistleblower Protection Officer.
  • The investigator will provide a report confirming the outcome of the investigation to the Whistleblower Protection Officer within 7 days of completing the investigation.
  • The Whistleblower Protection Officer will immediately make the report available to the Church’s Board Chair, the Senior Pastor, who will determine the appropriate action to take as a result of the investigation outcomes (in consultation with the Board as appropriate).

The Whistleblower Protection Officer will keep the Whistleblower informed generally regarding the progress of the investigation and the outcome of the investigation, subject to privacy considerations for any persons implicated in the report of Misconduct.

Persons implicated in Whistleblower report

Any persons implicated in allegations of Misconduct by a Whistleblower under this Policy are entitled to be afforded natural justice and procedural fairness during the course of the Church’s investigation of the alleged conduct. This shall include:

  • Being informed of the substance of the allegations;
  • Having the opportunity to be heard by the investigator about the substance of the allegations; and
  • Being informed of the outcome of the investigation.

Where allegations of Misconduct are not substantiated by an investigator’s report, any persons implicated in the allegations must be formally informed of the outcome of the investigation.

Where it is determined by a Whistleblower Protection Officer that a report is trivial, vexatious or baseless and no formal investigation is required, the Whistleblower Protection Officer may determine whether or not (in their sole discretion) to inform the person against whom any allegations of Misconduct are made that a report has been received and dismissed.

Personal work-related grievances

This Policy is concerned with the disclosure of instances of (or suspicions of) Misconduct as defined in Section 5 of this Policy only and is not intended to replace existing policy documents regarding complaints resolution, discrimination, harassment or bullying (except in circumstances where such behavior may constitute Misconduct as defined in this Policy).

Reports regarding personal work-related complaints will not be afforded protections under this Policy and will be referred to existing appropriate policy documents for alternative resolution mechanisms. To be clear, a personal work-related complaint will generally concern a complaint about any matter relating to the discloser’s employment having implications for the discloser personally, which does not constitute Misconduct as defined in Section 5 of this Policy.



Where a Whistleblower makes a report of actual or suspected Misconduct to a Whistleblower Protection Officer under this Policy, the Whistleblower Protection Officer must take all reasonable steps to keep the identity of the Whistleblower confidential unless disclosure of the Whistleblower’s identity is required by law.

The Whistleblower’s right to confidentiality regarding their identity (unless disclosure is required by law) may only be waived with the consent of the Whistleblower.

The Church acknowledges that in some instances, a Whistleblower may wish to make a report of Misconduct anonymously. However, it also acknowledges that a proper investigation may not be possible with an anonymous complaint, as the inability to make inquiries and seek further information from the disclosure may limit the scope of any potential investigation. For this reason, Whistleblowers are encouraged to make any reports of Misconduct without the condition of anonymity and rely on the assurances provided in this Policy regarding confidentiality of their identity.

Protection of Whistleblowers

The Church is committed to protecting the rights of a Whistleblower who reports Misconduct in accordance with the procedures set out in this Policy.

A Whistleblower must not be subject to any detriment, or the threat of detriment, for making a disclosure of Misconduct. Detriment may include, but is not limited to:

  • Dismissal of the Whistleblower as an employee, or alteration of the employee’s duties or position;
  • Discrimination against the Whistleblower as an employee as compared to other employees;
  • Harassment or intimidation of the Whistleblower;
  • Harm or injury to the Whistleblower (including psychological harm);
  • Damage to the Whistleblower’s property, reputation or business or financial interests;
  • Threats of any of the above.

Where a Whistleblower believes that they have been subjected to detriment for making a disclosure of Misconduct, the Whistleblower should raise these concerns with a Whistleblower Protection Officer as soon as practically possible.

Subjecting a Whistleblower to detriment for making a disclosure of Misconduct will itself be considered an instance of Misconduct and investigated in accordance with this Policy.

Where a Whistleblower is implicated in reports of Misconduct which are investigated and found to be substantiated, the protections under this Policy will not apply to any disciplinary action taken by the Church in relation to the Misconduct itself.


If you have a query about this Policy or need more information, please contact the General Manager.