MC Labour Group Whistleblower Policy

For the purpose of this Policy, MC Labour Group is comprised of the following companies:

  • MC Shared Services Pty Ltd ACN 626 481 418;
  • MC Labour Services Pty Ltd ACN 078 417 133;
  • MCLS (Aust) Pty Ltd ACN 169 551 571;
  • MC Security Services Pty Ltd ACN 120 583 084;
  • MC Traffic Management Pty Ltd ACN 154 671 539;
  • MC Height Safety Pty Ltd ACN 604 992 716;
  • Advance Labour Pty Ltd ACN 666 948 705;

and (together and separately (as applicable) MC Labour Group, MC Labour, Company, we, us, our).

1.  Purpose

The purpose of this policy is for the Company to meet legal and regulatory obligations by ensuring a safe environment for eligible person(s) to raise breaches of internal policies, rules or disclosable conduct relating to the Company, its branches, offices, employees, or members.

2.  Policy

MC Labour will provide the framework to ensure disclosures or complaints made regarding breaches of the Company’s internal rules and policies and Disclosable Conduct are investigated and fairly handled so that the person raising the complaint has no fear of reprisal.

Disclosable Conduct is defined under the Fair Work (Registered Corporations) Act (RO Act). In layman’s terms it covers breaking Commonwealth, State or Territory laws,

breaching registered or mandatory professional standards or codes of practice, or more broadly misconduct that includes maladministration, corruption, abuse of public trust, wastage, danger to health, safety or to the environment. Complaints

in relation to service levels, policy decisions or employment related grievances are out of scope and are handled by other internal policies such as the Discrimination, Harassment and Bullying Policy 1.4.

The following people can make a disclosure or complaint:

  • An officer or former officer of the Company, or one of its branches
  • An employee or former employee of the Company, or one of its branches
  • A member or former member of the Company, or one of its branches
  • A person who is (or was) a supplier to, or has (or had) a transaction with, the Company or one of its branches
  • A person who is (or was) a supplier to, or has (or had) a transaction with, an officer or employee of the Company or one of its branches
  • An employee (or former employee) of a supplier or person who had such a transaction1; or
  • A lawyer on behalf of a discloser in one of the above categories

2.1  Protection Afforded to Whistleblowers:


Information provided will be treated in strictest confidence. The Company will only share your details on a need to know basis with those within the Company who have a role to play in looking into your matter. In addition, there may be certain times under applicable law where the Company is required to share your details as part of its legal obligations.


MC Labour is committed to ensuring that if you raise a matter under this Policy, you are provided support and protection from reprisal or personal or financial disadvantage because of making that report. You are protected under the Registered Organisations Act (RO Act) when you raise a matter relating to Disclosable Conduct within your Company, just the same as you would have been if you had raised the Disclosable Conduct with the Registered Organisation Commission (ROC). This extended protection is another reason raising matters within your Company in the first instance is usually the quickest and most effective option.


Anonymous reports of wrongdoing are accepted under this Policy. Anonymous reports may have significant limitations that inhibit a proper and appropriate inquiry or investigation, such as the inability to provide feedback on the outcome and/or to gather additional particulars to assist the inquiry/ investigation.

2.2  Reporting

It is not acceptable to ‘walk past’ or ‘turn a blind eye’ to reportable matters; they should be reported as soon as possible to:

  • Your Manager
  • HR representative
  • Whistleblower Protection Officers (WPO), who are senior members of the Company responsible for receiving disclosers of wrongdoing when the person making the claim feels they cannot approach their Manager, HR or feel under threat or are fearful of reprisal. They also must be satisfied that the action taken in response to the inquiry/investigation is appropriate to the circumstances and that all investigations are carried out with procedural fairness.
  • Whistleblower hotline.
    • Your Call: 1300 788 712
    • Email:
    • Head office: Suite 3, 400 High Street, Kew VIC 3101.
  • To external agencies such as: the Registered Organisation Commission (ROC), Fair Work Commission (FWC) or Fair Work ombudsman, Australian Building and Construction Commission (ABCC)

Reports can be made anonymously.

When making a complaint you will need to provide as much information as possible, this includes dates, times, location, individuals involved, other witnesses, physical evidence (e.g. documents, images) and any other general information that may be helpful to assist the Company to determine how to take appropriate action.

2.3   Assessment:

Any information provided may be used by the Company in assessment of actions required. This can include:

  • An investigation (either internally or via independent external investigators)
  • The matter being resolved by speaking to one or more parties
  • The matter being recorded and monitored going forward
  • Referred to another agency or a combination of the above
  • Where practicable, you will be contacted and advised of what action will be undertaken

2.4   Investigation:

If the Company determines that your matter should be investigated, the investigation may be conducted by the Whistleblower Investigation Officer (WIO), an appropriately capable officer or employee of the Company nominated by the WIO, or by an external investigator appointed by the Company. All investigations will be conducted in a manner that is procedurally fair, confidential, without bias and in a timely manner.

Unless the report was made anonymously, you will be informed of the outcome of the investigation by the Company. The Company may in certain circumstances, whether required by law or in its discretion, inform the ROC, the Fair Work Commission, or the relevant authority of any contents of the investigation.

2.5  Further Information:

For further information see Whistleblower Procedure and the Registered Organisation Commission’s website

2.  Failure to comply with this Policy

Any breach of this Policy may result in disciplinary action, including dismissal from the Company.

3.  Review

This policy will be reviewed annually.

4.  Authorisation

Authorised by the Managing Director.

Marc Lunedei



Whistleblower | Document Identification 1.17 | Version 5.1 | Date Authorised 120224