July 2025
Longreach Alternatives Ltd (‘Longreach’) is committed to conducting business activities efficiently, honestly, and fairly. All Longreach staff and representatives are required to maintain a high level of standard aligned to Longreach’s Code of Conduct, and all other policies and procedures when conducting business activities. Longreach takes any unlawful and unethical behaviour very seriously, and so if you suspect that something is not right or if have concerns on any matters, Longreach encourages you to speak up as soon as possible. As an organisation, Longreach enforces a culture of open and honest communication, and accountability which allows for conducting business activities in line with legislative and regulatory requirements including:
- Treasury Amendment (Enhancing Whistleblower Protections) Act 2019 (Cth);
- Corporations Act 2001 (Cth);
- ASIC Guidance for Whistleblowers INFO 52.
This Whistleblower Policy (‘Policy’) outlines the guidelines for how to raise a whistleblower case and how Longreach will manage it in accordance with all applicable requirements.
Purpose
This policy outlines the guidelines in place to help individuals in how to raise a concern regarding a suspected or actual unethical or unlawful behaviour. It is noted that this policy does not restrict or diminish one’s right or ability to make a disclosure directly to regulatory bodies such as ASIC.
The Longreach Board and affiliated entities are committed to providing support and protecting the wellbeing, career and reputation of any individual seeking to report any wrongdoing. All personnel should feel confident and without discomfort, or concerns for retaliation or adverse action to report any cases of alleged wrongdoing even if the allegation is not upheld. Any and all cases reported under this policy are treated seriously and are to be investigated with discretion.
Disclosable Matters
A Reportable Matter is any concern (actual or suspected) about a particular conduct, or a deliberate concealment of such conduct. Examples may include:
- Illegal, dishonest, corrupt, or unethical conduct;
- Theft;
- Dealing in or use of illicit drugs;
- Violence or threatened violence;
- Criminal damage against property;
- Fraud;
- Money laundering;
- Discrimination;
- Vilification;
- Harassment;
- Bullying;
- Victimisation;
- Misappropriation or mismanagement of Longreach resources or funds;
- Offering or accepting a bribe;
- Financial irregularities;
- Failure to comply with, or breach of, legal or regulatory requirements;
- Suspected accounting or auditing practices that may have material impact on Longreach on behalf of the investor, regulatory compliance, funds offered by Longreach, the investment manager,
- Longreach’s financial position, regulatory compliance or reputation;
- Engaging in or threatening to engage in detrimental conduct against a person who has made a disclosure, or is believed or suspected to have made, or be planning to make, a disclosure.
Matters not covered in this Policy
It is noted that this policy does not cover conduct matters that are not considered Reportable Conduct, such as work-related grievances, which may include:
- an interpersonal conflict between the discloser and another employee;
- a decision that does not involve a breach of workplace laws;
- a decision relating to the discloser’s engagement, transfer or promotion;
- a decision relating to the terms and conditions of the discloser’s engagement; or
- a decision to suspend or terminate the discloser’s engagement, or otherwise to discipline the discloser.
However, personal work-related grievances may still qualify for protection if:
- it includes information about misconduct, or information about misconduct includes or is accompanied by a personal work-related grievance (mixed report);
- Longreach has allegedly breached employment or other laws punishable by imprisonment for a period of 12 months or more, engaged in conduct that represents a danger to the public, or the disclosure relates to information that suggests misconduct beyond the discloser’s personal circumstances;
- the discloser suffers from or is threatened with detriment for making a disclosure; or
- the discloser seeks legal advice or legal representation about the operation of the Whistleblower protections under the Corporations Act.
False Reporting
It is noted that a false report of Disclosable Matters may have a significant impact on Longreach’s reputation and staff. Any deliberate cases of false reporting by staff of Disclosable Matters will be treated as a significant disciplinary matter for Longreach to take reasonable action.
Whilst not intending to discourage reporting Disclosable Matters of genuine concern, Whistleblowers must ensure that the reports are factually accurate as much as possible to have reasonable grounds to suspect. This includes having first-hand knowledge, having been presented in an unbiased fashion (where any possible perceptions of bias should be disclosed) and without material omission.
Raising a Whistleblower Report
For a whistleblower report to be considered thoroughly, the matter should include as much detail as possible to form reasonable grounds for investigation to proceed. This includes any known details of:
- Date and time of the Disclosable Matter;
- Name of entity and/or individuals involved;
- Possible witnesses of the Disclosable Matter;
- Any evidence regarding the Disclosable Matter.
- Additionally, if you have taken any steps already to report or resolve the matter elsewhere (e.g., media, regulatory body, etc.), include these details when raising the whistleblower report.
A Whistleblower Report may be made in person, by telephone, online or in writing (including email). It is strongly recommended that an Eligible Whistleblower make their report in writing. Disclosures may also be made anonymously and/or confidentially, securely and outside of business hours.
The primary channel for raising Whistleblower Reports is via the Whistleblower Protection Officer at the Longreach Compliance inbox (compliance@longreachalternatives.com).
Additional Reporting Channels
In addition to raising a report to the Whistleblower Protection Officer, you may also raise via:
- Chair and/or Director of Longreach’s Board; or
- Company Secretary of Longreach’s Board;
- Further, disclosure to the following parties also qualify for protection as a whistleblower:
- Legal adviser for the purposes of obtaining or seeking legal advice or representation in relation to whistleblower provisions under the Corporations Act 2001 (Cth);
- Regulatory or Commonwealth bodies e.g., ASIC, APRA, etc.;
- Journalist or parliamentarian where it is a public interest disclosure or emergency disclosure.
- It is advised that disclosers wishing to raise a matter seek independent legal advice prior to making such a disclosure.
Confidentiality
Longreach will ensure reasonable steps are taken to keep whistleblower reports confidential to the extent possible, subject to legal and regulatory requirements. You can make disclosures to the Whistleblower Protection officer anonymously or by using a pseudonym. If you choose to disclose anonymously or by using a pseudonym, note this may hinder the ability of Longreach to fully investigate the matter.
The identity of the Whistleblower will be protected in accordance with the applicable laws and, except as authorised, Longreach will not reveal the identity of the Eligible Whistleblower, or information likely to lead to the Eligible Whistleblower’s identification without their consent. Where considered necessary, Longreach may contact Whistleblower to request consent to reveal the identity to other persons, including Longreach’s external legal advisers, the Whistleblower Protection Officer, members of the Risk and Compliance Committee, and the Longreach Board. The unauthorised release of information without an Eligible Whistleblower's consent to any person not involved in the investigation (other than the Whistleblower Protection Officer) is a breach of this Policy, and is subject to any requirements of applicable law.
Investigations
Longreach will conduct investigations into the whistleblower report and record all concerns confidentially, objectively, and fairly. The process may vary dependent on the nature of the matter being investigated. The purpose of the investigation is to determine whether the concerns are substantiated or not, assessing the situation including root cause, and rectifying any wrongdoing revealed to the extent that is it practicable in all circumstances.
Communications
Once the investigation is completed, communications will be made to you to inform on the outcome of the investigation. Potential outcomes include:
- Whether the concern was substantiated with any appropriate actions taken;
- Whether the concern was not substantiated and no further action will be taken unless further evidence becomes available;
- A determination was not made as a result of the investigation with no further action being taken unless further evidence becomes available.
Longreach may contact you to provide further feedback on the matter during the investigation process, subject to the privacy and confidentiality rights of the individual under investigation and any other confidentiality requirements.
Whistleblower Protection
Longreach understands that whistleblowers may be deterred or worried about possible repercussions from making a disclosure. If there are reasonable grounds to suspect a disclosable matter had occurred, even if the concerns were mistaken, Longreach will take the matter seriously and will support and protect you throughout the process. Additionally, Longreach will also provide the relevant protection and support available as outlined in this policy to those not directly employed by Longreach at the time the report is made.
Longreach must protect you by ensuring the confidentiality throughout the investigation process, and protecting as far as legally possible your identity (particularly when consent is not provided to disclose).
Threats to cause detriment to the Whistleblower (whether express, implied, conditional or unconditional) are prohibited, whether or not the person threatened actually fears that the threat will be carried out. Any individual found to be victimising or disadvantaging someone from making a disclosure will be disciplined per Longreach’s internal consequence management procedures. If it is believed that you suffered personal disadvantage in violation of this policy, we encourage you to report this matter immediately.
This policy does notes that the protections provided do not grant immunity for any misconduct a discloser had engaged in that is revealed in the disclosure.
Contact Us
If you have any questions about this Policy, have concerns, or would like to enquire further, please contact the Longreach Compliance Team at compliance@longreachalternatives.com.
