Whistleblower Policy

At EatFirst, we are guided by our company values. These values are the foundation of how we conduct ourselves and interact with our clients and suppliers. EatFirst is committed to ensuring corporate compliance and promoting ethical corporate culture by observing the highest standards of fair dealing, honesty, and integrity in our business activities.

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Purpose

The policy has been put in place to ensure any concerns raised regarding any misconduct or an improper state of affairs or circumstances in relation to the EatFirst’s business are dealt with effectively, securely, appropriately, and in accordance with the Corporations Act 2001 (Cth) (the Act).

EatFirst encourages the reporting of any instances of suspected unethical, illegal, corrupt, fraudulent, or undesirable conduct involving the Company’s business. Further, EatFirst provides protections and measures to individuals who make a disclosure in relation to such conduct without fear of victimization or reprisal.

This policy will be provided to all employees upon commencement of their employment or engagement.

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Scope

This policy applies to any person who is, or has been, any of the following with respect to EatFirst:

  • Employee
  • Management team
  • Management director
  • Contractor
  • Supplier

This policy is intended to apply to the above persons in all countries in which EatFirst operates a business.

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Reportable Conduct

You may make a report or disclosure under this policy if you have reasonable grounds to believe that an employee, management team member, director, and supplier or another person who has business dealings with the Company has engaged in conduct (Reportable Conduct) which is:

  • Dishonest, fraudulent, or corrupt;
  • Illegal (such as theft, dealing in or use of illicit drugs, violence or threatened violence and criminal damage to property, forced labour or any form of modern slavery);
  • Potentially damaging to the Company, its employees or a third party;
  • A danger, or represents a danger to the public or financial system;
  • Harassment, discrimination, victimization or bullying.

Any disclosures that do not fall within the definition of Reportable Conduct will not qualify for protection under the Act. It will be at the Company’s discretion whether it considers there is a reasonable suspicion that the Reportable Conduct is occurring and/or whether the conduct constitutes “misconduct or an improper state of affairs” under the Act.

For the avoidance of doubt, Reportable Conduct does not include personal work-related grievances. A personal work-related grievance is a grievance about any matter in relation to a staff member’s current or former employment, having implications(or tending to have implications) for that person personally and that do not have broader implications for the Company. Examples of personal work-related grievances are as follows:

  • An interpersonal conflict between the staff member and another employee
  • A decision relating to the engagement, transfer, or promotion of the staff member
  • A decision relating to the terms and conditions of engagement of the staff member
  • A decision to suspend or terminate the engagement of the staff member, or otherwise to discipline the staff member A personal work-related grievance should be reported to the relevant or responsible manager or in accordance with the Dispute Resolution Policy.

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Making A Disclosure

The Company relies on its employees maintaining a culture of honest and ethical behaviour. Accordingly, if you become aware of any Reportable Conduct, it is expected that you will make a disclosure under this policy.

There are several ways in which you may report or disclose any issue or behaviour which you consider to be Reportable Conduct.

Internal Reporting

You may disclose any Reportable Conduct to the Whistleblower Protection Officer listed below:

Managing Director for EatFirst in Australia, New Zealand and Singapore
Markus Albert
markus.albert@eatfirst.com.au

You can make a disclosure outside of business hours by contacting the above Whistleblower Protection Officers via email.

You are also encouraged to contact the above Whistleblower Protection Officer to obtain any additional information you may require before making a disclosure or for any clarification regarding this policy.

Anonymity

When making a disclosure, you may do so anonymously. It may be difficult for the Company to properly investigate the matters disclosed if a report is submitted anonymously. Therefore, EatFirst encourages you to share your identity when making a disclosure; however, you are not required todo so.

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Investigation

EatFirst will investigate all matters reported under this policy as soon as possible after the matter has been reported. The Whistleblower Protection Officer will investigate the matter and, where necessary, appoint an external investigator to assist in conducting the investigation or refer the matter to the relevant authority. All investigations will be conducted in a fair, independent, and timely manner, and all reasonable efforts will be made to preserve confidentiality during the investigation.

If the report is not anonymous, the Whistleblower Protection Officer or external investigator will contact you by your preferred method of communication to discuss the investigation process and anyother matters that are relevant to the investigation.

Where you have chosen to remain anonymous, your identity will not be disclosed to the investigator or to any other person, and EatFirst will conduct the investigation based on the information provided to it.

To the extent permitted by law, the Whistleblower Protection Officer may inform you and/or a person against whom allegations have been made of the findings. The Company will document the findings ina report; however, any report will remain the property of the Company and will only be shared with you or any person against whom the allegations have been made if the Company deems it appropriate.

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Protection of Whistleblowers

The Company is committed to ensuring that any person who makes a disclosure is treated fairly and does not suffer detriment and that confidentiality is preserved in respect of all matters raised under this policy.

Protection from Legal Action

You will not be subject to any civil, criminal, or administrative, legal action (including disciplinary action) for making a disclosure under this policy or participating in any investigation.

Protection of Confidentiality

All information received from you will be treated confidentially and sensitively. You will not be required to provide your name when making a disclosure. To make a disclosure on an anonymous basis, it is recommended that you use a pseudonym and contact the Whistleblowing Protection Officers in the manner outlined above.

If you report on an anonymous basis, you will still qualify for the protections in this policy

If you make a disclosure under this policy, your identity (or any information which would likely identify you) will only be shared if:

You give your consent to share that information; or

  • The disclosure is allowed or required by law (for example, where the concern is raised with a lawyer for the purposes of obtaining legal advice); or
  • The concern is reported to the Australian Securities and Investments Commission (ASIC),the Australian Prudential Regulation Authority (APRA), the Australian Taxation Office (ATO) or the Australian Federal Police (AFP);

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Other Matters

In so far as this policy imposes any obligations on the Company, those obligations are notc ontractual and do not give rise to any contractual rights. To the extent that this policy describes benefits and entitlements for employees, they are discretionary in nature and are also not intended to be contractual. The terms and conditions of employment that are intended to be contractual a reset out in an employee’s written employment contract.

The Company may unilaterally introduce, vary, remove or replace this policy at any time.

Employees are encouraged to read this policy in conjunction with other relevant Company policies (EatFIrst Company Handbook), including:

  • Discrimination and Harassment Policy
  • Dispute resolution Policy
  • Modern Slavery Policy