Legal
Whistleblower Policy
Purpose
This policy is issued by Cohabit Technology Group Pty Ltd ("Company", "we", "our") and applies to all entities in the Cohabit Group, including Contega Pty Ltd trading as Contega Risk Advisory. The Company is committed to lawful, ethical, and responsible conduct across its insurance brokerage and risk advisory operations.
This policy establishes a safe, confidential, and legally compliant process for reporting misconduct or improper conduct without fear of retaliation.
We encourage the reporting of concerns to ensure:
- Compliance with AFSL and Corporations Act obligations
- Integrity in client dealings
- Protection of confidential and personal information
- Maintenance of public trust in our services
Scope
This policy applies to:
- Employees (permanent, part-time, casual)
- Directors and officers
- Contractors and consultants
- Brokers and authorised representatives
- Suppliers and service providers
- Former employees and associates
- Relatives and dependants of eligible whistleblowers
This policy applies across all business units including insurance broking and placement, risk advisory, and claims handling and advice services.
What can be reported?
A disclosure may be made if a person has reasonable grounds to suspect misconduct or improper conduct. Examples include, but are not limited to:
Insurance brokerage conduct
- Breaches of AFSL obligations
- Conflicted remuneration or undisclosed commissions
- Misleading or deceptive conduct
- Failure to act in client best interests
- Improper claims handling practices
- Fraudulent placement or premium misrepresentation
Privacy and data protection
- Unauthorised access to personal or client data
- Breach of the Privacy Act or APPs
- Improper data sharing
- Security vulnerabilities knowingly ignored
- Failure to notify eligible data breaches
Corporate and financial misconduct
- Fraud, theft, or corruption
- Accounting irregularities
- False financial reporting
- Insider trading or misuse of confidential information
Regulatory or legal breaches
- Breaches of the Corporations Act
- ASIC reporting failures
- AML/CTF non-compliance
- Modern slavery violations
- Tax evasion
Retaliation
- Victimisation of a whistleblower
- Threats, harassment, or intimidation
What is not covered?
This policy does not cover personal work-related grievances (unless they relate to victimisation or systemic misconduct), performance disputes, or interpersonal conflicts unrelated to misconduct. Such matters should be addressed under HR grievance procedures.
Who can receive a disclosure?
Disclosures may be made to a Director, the Responsible Manager (AFSL), the Head of Compliance or Risk, the Company Secretary, external legal counsel, or an ASIC-authorised auditor.
Alternatively, disclosures may be made directly to ASIC, APRA (if applicable) or a legal practitioner for advice.
How to make a disclosure
Reports may be made in writing (email or secure form), verbally (phone or in person), or anonymously.
Company contact: compliance@contega.com.au
Anonymous disclosures are permitted and will be treated seriously.
Confidentiality and anonymity
The Company will keep the whistleblower's identity confidential, not disclose identifying information without consent, remove identifying details where practical, and store records securely. Identity may only be disclosed where required by law. Unauthorised disclosure of a whistleblower's identity is a serious offence.
Protection against detriment
The Company strictly prohibits retaliation, including dismissal, demotion, harassment, discrimination, injury or damage, threats or intimidation. Anyone found engaging in retaliation will face disciplinary action, including termination. Whistleblowers are protected under the Corporations Act 2001 (Cth).
Investigation process
Upon receiving a disclosure:
- The matter is acknowledged (where possible).
- A preliminary risk assessment is conducted.
- An independent investigator may be appointed.
- Relevant documents and systems may be reviewed.
- Findings are reported to the Board or appropriate authority.
- Corrective action is implemented where required.
Investigations will be fair, impartial, conducted confidentially and completed within a reasonable timeframe. Where appropriate, the whistleblower will be informed of progress.
Fair treatment of individuals mentioned
The Company will treat all individuals fairly, maintain confidentiality, provide an opportunity to respond to allegations, and avoid reputational harm unless findings support action.
Record keeping
All disclosures will be logged in a secure register, assigned a unique case reference, documented in accordance with compliance obligations, and reported to the Board (de-identified where appropriate).
Regulatory reporting
Where required, the Company will report matters to ASIC, APRA (if relevant), the OAIC (for privacy breaches) or AUSTRAC (for AML/CTF issues).
False or malicious reports
Making a report that is knowingly false or malicious may result in disciplinary action. However, a report made in good faith will not result in consequences, even if unsubstantiated.
Policy review
This policy will be reviewed annually, upon regulatory change, and following any material whistleblower event.