Whistleblower Policy


Our Policy Statement

Healthy Land and Water is a profit for purpose community-based natural resources management business supporting resilient regions.


Our Mission

Our mission is to promote an organisational culture that encourages ethical conduct and is committed to compliance, legal requirements, our policies and procedures and to act in good faith at all times. We will encourage and support our employees who, acting in good faith, raise concerns about any breach of our policies, our statutory and/or legal obligations or our code of conduct.


Our Strategies and Objectives

The organisation is committed to the new whistleblower protection regime covering the corporate, financial and tax sectors. The Treasury Laws Amendment (Enhancing Whistleblower Protections) Act 2019 (Act) aims to encourage ethical whistleblowing and discourage white collar crime, while holding employers accountable for protecting eligible whistleblowers.


The Act makes important changes to the Corporations Act 2001 (Cth) and the Taxation Administration Act 1953 (Cth) affecting almost all companies, including foreign corporations, trading or financial corporations formed within the limits of the Commonwealth, ADIs, NOHCs, super funds, and insurers.



Our Responsibilities

As an organisation we acknowledge the following key reforms:

  • Protected disclosures may relate to matters beyond criminal breaches, including breaches of tax laws, ASIC laws and APRA laws. Conduct that is not illegal but indicates systemic issues will also be disclosable. However, the protections will not extend to disclosures about personal employment or workplace grievances such as interpersonal conflicts, transfer, promotion, or disciplinary decisions.
  • More people can be ‘eligible whistleblowers’, including anyone who has ever been in a relationship with a company (such as former employees, contractors, employees of contractors, associates, and relatives of such individuals).
  • More people can be ‘eligible recipients’ of disclosures, including senior managers, directors and auditors; and in certain circumstances, even journalists and politicians.
  • Stronger protections for whistleblowers including anonymity, increased immunities against prosecution, and protection against detriment through victimisation. Whistleblowers are no longer required to act in good faith to be protected (although they need to have reasonable grounds to suspect misconduct).


Our Governance

The organisation understands that severe civil and criminal penalties will apply to employers who breach those protections, and courts are empowered to make orders for relief against a company, if they fail to fulfil a duty of care to protect a whistleblowing employee from detriment. The maximum civil penalties under the new Treasury Laws Amendment (Strengthening Corporate and Financial Sector Penalties) Act 2019 (Cth) for breaching confidentiality of an eligible whistleblower’s identity or causing or threatening detriment include significant penalties for individuals and companies.


To comply with section 1317AI, this policy must be read with the Whistleblower Procedure which contains:

  • the protections available to whistleblowers;
  • how and to whom an individual can make a disclosure;
  • how the company will support and protect whistleblowers;
  • how investigations into a disclosure will proceed;
  • how the company will ensure fair treatment of employees who are mentioned in whistleblower disclosures; and
  • how the policy will be made available.


Get in touch

Healthy Land and Water is dedicated to the care of our unique and beautiful land, waterways and biodiversity.

  • Address: Level 19, 160 Ann Street Brisbane QLD 4000
  • PO Box: 13204, George Street Brisbane QLD 4003
  • Phone: (07) 3177 9100
  • Fax: (07) 3177 9190
  • Email: info@hlw.org.au

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