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Whistleblower policy

Who is covered by this policy?

This policy applies to protected disclosures made by:

  • an officer, employee, former employee or contractor of Adelaide Tools or Oaklands Mower Centre (Adelaide Tools)
  • an individual who supplies goods or services to Adelaide Tools
  • an employee of a person or entity who supplies goods or services to Adelaide Tools (whether paid or unpaid)
  • an individual who is an associate of Adelaide Tools (meaning a director or secretary of Adelaide Tools and Oaklands Mower Centre) or of its related bodies corporate, or a person acting in concert with Adelaide Tools); and
  • a relative or dependant of any of the persons listed above.

What is Reportable Conduct?

You may make a report under this policy if you objectively have reasonable grounds to suspect that an Adelaide Tools director, officer, team member, contractor, supplier, tenderer or other person who has business dealings with Adelaide Tools has engaged in conduct ("Reportable Conduct") which:

  • is dishonest, fraudulent or corrupt, including bribery or other activity in breach of the Wesfarmers Anti-bribery Policy;
  • is illegal activity (such as theft, violence, harassment or intimidation, criminal damage to property or other breaches of state or federal law);
  • is unethical or in breach of Adelaide Tools’ policies (such as dishonestly altering company records or data, adopting questionable accounting practices or wilfully breaching Wesfarmers’ Code of Conduct or Adelaide Tools’ other policies or procedures);
  • is potentially damaging to Adelaide Tools, an Adelaide Tools team member or a third party, such as unsafe work practices, environmental damage, health risks or abuse of Adelaide Tools' property or resources;
  • amounts to an abuse of authority;
  • may cause financial loss to Adelaide Tools or damage its reputation or be otherwise detrimental to Adelaide Tools’ interests; or
  • involves any other kind of misconduct or an improper state of affairs or circumstances.

What is not reportable conduct?

This policy is not intended to apply to disclosures relating to conduct concerning a person’s individual employment or former employment (other than as set out in Reportable Conduct), such as:

  • an interpersonal conflict at work;
  • a decision relating to engagement, transfer or promotion;
  • a decision relating to terms and conditions of engagement; or
  • a decision to suspend or terminate the engagement or to discipline the person.

These matters will not be deemed to be Reportable Conduct, do not fall within the scope of this policy, and will typically be investigated or addressed separately under Adelaide Tools’ Respectful Workplaces Policy.

Who can I make a report to?

Adelaide Tools has several channels for making a report if you become aware of any issue or behaviour which you consider to be Reportable Conduct:



To Speak Up (independent third-party)

A report may be made via the Adelaide Tools Speak Up Service: a free external hotline and reporting service independently monitored by Deloitte.

Speak Up reporting options are:

  • by phone: 1800 176 386
  • by email:
  • web-based access:
  • by post: Speak Up

                                Reply Paid 12628

                                A’Beckett Street

                                Melbourne VIC 8006

Reports may be made anonymously, but if you provide your contact details to Speak Up, those contact details will only be provided to Adelaide Tools if you consent.

To a

Protected Disclosure Officer

In order to ensure appropriate escalation if a disclosure is made internally, and timely investigation, we request that reports are made to any one of our Protected Disclosure Officers, listed below:

Michael Schneider                       Phone: +61 3 8831 9670

Managing Director

Jacqui Coombes                          Phone: +64 9 978 2242

Director HR & NZ

Justin Williams                             Phone: +61 8 9365 1706

Chief Financial Officer

By post

Reports may also be posted to c/- Locked Bag 3004, Hawthorn, Victoria, 3122 (marked Private & Confidential and to the attention of one of the Protected Disclosure Officers).

In order to qualify for protection, the disclosure must be made to one of the recipients outlined above, or any other recipient prescribed by law, such as an “officer” or “senior manager” of the company (includes a director, or a senior manager in the company who makes, or participates in making, decisions that affect the whole, or a substantial part, of the business of the company, or who has the capacity to affect significantly the company’s financial standing), the relevant regulator or Adelaide Tools’ auditor.

Adelaide Tools’ investigation of Reportable Conduct

Adelaide Tools will investigate all Reportable Conduct reported under this policy as soon as practicable after the matter has been reported. Speak Up, or a Protected Disclosure Officer may, with your consent, appoint a person to assist in the investigation of a report. Where appropriate, Adelaide Tools will provide feedback to you regarding the investigation’s progress and/or outcome (subject to considerations of the privacy of those against whom allegations are made).

The investigation will be conducted in an objective and fair manner, and otherwise as is reasonable and appropriate having regard to the nature of the Reportable Conduct and the circumstances.

While the particular investigation process and enquiries adopted will be determined by the nature and substance of the report, in general, as soon as practicable upon receipt of the report, if the report is not anonymous, a Protected Disclosure Officer or delegate will contact you to discuss the investigation process, including who may be contacted and such other matters as are relevant to the investigation.

Where a report is submitted anonymously, Adelaide Tools will conduct the investigation and its enquiries based on the information provided to it.

Protection of Whistleblowers

Adelaide Tools is committed to ensuring confidentiality in respect of all matters raised under this policy, and that those who make a report are treated fairly and do not suffer detriment.

  • Protection against detrimental conduct

Detrimental treatment includes dismissal, demotion, harassment, discrimination, disciplinary action, bias, threats or other unfavourable treatment connected with making a report.

If you are subjected to detrimental treatment as a result of making a report under this policy you should:

  • inform a Protected Disclosure Officer, officer or senior manager of Adelaide Tools immediately; or
  • raise it in accordance with this policy.
  • Protection of your identity and confidentiality

Subject to compliance with legal requirements, upon receiving a report under this policy, Adelaide Tools will only share your identity as a whistleblower or information likely to reveal your identity if:

  • you consent;
  • the concern is reported to the Australian Securities and Investments Commission ("ASIC"), the Australian Prudential Regulation Authority ("APRA"), the Tax Commissioner or the Australian Federal Police ("AFP"); or
  • the concern is raised with a lawyer for the purpose of obtaining legal advice or representation.

If Adelaide Tools needs to investigate a report, it may disclose information that could lead to your identification, but it will take reasonable steps to reduce this risk.

Any disclosures of your identity or information likely to reveal your identity will only be made to an employee, advisor or contractor of Adelaide Tools, or Wesfarmers Limited, who reasonably has a need to investigate, report on, or respond to, the matters raised in your disclosure.

  • Protection of files and records

All files and records created from an investigation will be retained securely.

Unauthorised release of information to someone not involved in the investigation (other than senior managers or directors who need to know to take appropriate action, or for corporate governance purposes) without your consent as a whistleblower will be a breach of this policy.

Whistleblowers are assured that a release of information in breach of this policy will be regarded as a serious matter and will be dealt with under Adelaide Tools’ disciplinary procedures.

The Corporations Act 2001 (Cth) (“Corporations Act”) gives special protection to disclosures about breaches of that Act, provided certain conditions are met – refer to Annexure A for further details.

The Taxation Administration Act 1953 (Cth) ("Taxation Administration Act") also gives special protection to disclosures about breaches of any Australian tax law, provided certain conditions are met – refer to Annexure B for further details.

Duties of team members in relation to Reportable Conduct

It is expected that Adelaide Tools’ team members who become aware of actual or suspect on reasonable grounds, potential cases of Reportable Conduct, will make a report under this policy or under other applicable policies.

Reporting procedures

Protected Disclosure Officers will report to the Adelaide Tools and Wesfarmers boards on the number and type of whistleblower incident reports annually, to enable Wesfarmers to address any issues at a divisional/business unit and/or Group level. These reports will be made on a ‘no names’ basis, maintaining the confidentiality of matters raised under this policy.

The Wesfarmers Audit and Risk Committee will receive copies of all Adelaide Tools whistleblower reports, and whistleblower reports from Protected Disclosure Officers (as appropriate). In addition, serious and/or material Reportable Conduct will be considered by the Protected Disclosure Officers for immediate referral to the Chairman of the Wesfarmers Audit and Risk Committee.

Operation and Amendment of this policy

This policy:

  • operates in addition to the Wesfarmers Whistleblower Policy and, in the event of any inconsistency with the Wesfarmers Whistleblower policy, the Wesfarmers Whistleblower policy will prevail to the extent of the inconsistency;
  • cannot be amended without approval of the Adelaide Tools Board. It will be reviewed from time to time to ensure that it remains effective and meets best practice standards and the needs of Adelaide Tools.


Last amended 04-MAY-2020