Whistleblower

Navantia Australia supports a “SPEAK UP’ culture and encourages its internal, external stakeholders and general public to disclose any suspected or concerned activities related to Navantia Australia, including the following:

• Any breaches against Navantia Australia’s Code of conduct, values, and internal policies
• Any misconducts including fraud, corruption, bribery, negligence, or breach of trust that can bring Navantia Australia or the Navantia Group into disrepute and breach of duty.
• Any offences against Corporation Acts 2001, Taxation Administration Act 1953, Criminal Code Act 1995, or any other relevant regulations.
• Any serious misconducts as defined under the Fair Work Regulations 2009, which covers conduct that causes serious or imminent risk to the health or safety of a person, or the reputation, viability or profitability of the employer’s business.
• Any offences punishable by imprisonment.

You are encouraged to report any disclosable matters where you have reasonable ground to suspect concerns misconduct or improper state of affairs or circumstances in relation to Navantia Australia.

Navantia Australia is an ethical and transparent organisation. Your disclosure will help us identify and properly address problems in Navantia Australia’s administration, contributing to the continual improvement to our organisation in the following ways:

• Mitigating the risks of economic loss, reputational damage to our organisation or danger to health and safety of involved individuals.
• Implementing processes for reporting and dealing with wrongdoing contributes to the integrity of Navantia Australia.
• Making improvements to our processes in preventing fraud, corruption, or any violations to our Code of conduct, policies, and regulatory requirements.
• Strengthening defence and community’s trust in public administration by having strong processes in place for reporting misconducts and governing compliance.

In accordance with the Public Interest Disclosure (PID) Act 2022, all disclosures received by Navantia Australia will be initially treated as PID, until the initial triage is completed. As such, you will be eligible for confidentiality and protection rights as per following:

• Safety of the discloser (or witnesses or affected third parties).
• Identity of the discloser and confidential information about PID.
• Protect discloser from detrimental conduct (harm) and victimisation.
• Immunity from liability if discloser has not engaged in the wrongdoing.
• Protection from defamation.

After the completion of the initial triage, those protection rights will remain if the disclosure is classified to be a PID matter. If the matter is not a PID, these protections will still be considered.

If the disclosure is classified as a PID matter, and contact details were provided, you will receive a response within 72 hours of your disclosure indicating that the reported issue will undergo a preliminary investigation as a PID matter.
If the disclosure is classified as not a PID matter, Navantia Australia will resolve the reported issue through one of our internal governance processes and you will receive a response about this decision.

If the reported issue is a PID matter, the outcomes of the disclosure will be communicated to you via any contact details that you may have provided. You will be notified about the resolution and corrective actions for your disclosure.

If the disclosure is not a PID matter, you will not be notified when the matter is resolved.

Yes, you can choose to submit your report anonymously through our Anonymous Reporting Form. 

Note: It is encouraged that you provide us with contact details to aid with the investigation.

Navantia Australia will conduct an initial triage assessment on your disclosure to determine its PID status. If the matter is deemed as a non PID matter, Navantia Australia will initiate a review and utilize an internal process (grievance, disciplinary) to resolve the issue. Investigation and disciplinary actions might be issued against respondents’ dependent on the severity of the allegations and whether they were substantiated.

If the disclosure is deemed as a PID matter, it cannot be withdrawn, an investigator will be appointed, and relevant stakeholders will be consulted to resolve the PID.

In some instances, Navantia Australia might decide to refer the PID to another proper authority because:

• The PID concerns wrongdoing by that agency.
• The agency has the power to investigate and resolve the matter.

To assess the likelihood of discloser suffering reprisal action from submitting the disclosure, Navantia Australia will conduct risk assessment to identify risks, and mitigation strategies will be implemented to ensure discloser’s protections.

Our ability to contact you is dependent on the contact details that you included in your disclosure submission. You can voluntarily provide us your contact email, phone number or mail address. If you choose to report the disclosure anonymously, Navantia Australia will not be able to communicate with you.

Navantia Australia has developed and published a list of documentations to governing our compliance framework, which includes the following:
+ Code of Conduct
+ Compliance Manual
+ Anti-Corruption, Modern Slavery, Privacy, and Security Policies
+ Whistleblower Procedure
+ Anti-Corruption and Compliance Procedure
+ Gifts and Benefits Procedure
+ Crime Prevention Procedure.

If you have any questions, the listed channels below can further assist you with any inquiries:

Commonwealth Ombudsman: https://www.ombudsman.gov.au/ for more information about PID process and complaints

Federal Register of Legislation: https://www.legislation.gov.au/ for more information about compliance Acts and regulations.

Navantia Australia email: pid@navantia.com.au for more information about our internal compliance framework and how we manage and resolve disclosures.