Whistleblower Policy

Count Limited (‘Company’) is committed to best practice in corporate governance, compliance and ethical behaviour. To assist in the prevention and detection of fraud, corruption and misconduct, the Company has adopted a Whistleblower Policy (the Policy) that provides a framework for bringing suspected corrupt, illegal or unethical behaviour (improper conduct) to the attention of management while at the same time protecting the confidentiality of the individuals who, in good faith, report such conduct. 

Whistleblower Policy

Count Limited (‘Company’) is committed to best practice in corporate governance, compliance and ethical behaviour. To assist in the prevention and detection of fraud, corruption and misconduct, the Company has adopted a Whistleblower Policy (the Policy) that provides a framework for bringing suspected corrupt, illegal or unethical behaviour (improper conduct) to the attention of management while at the same time protecting the confidentiality of the individuals who, in good faith, report such conduct. 
Download the Full Policy View PDF (June 2026)

Summary of Policy

This policy outlines the procedure for managing misconduct, or an improper state of affairs or circumstances, relating to Count, including:

  • who can make a report;
  • what is a Disclosable Matter;
  • how to report a Disclosable Matter;
  • the investigation process;
  • protections provided to you if you make a report; and
  • ensuring fair treatment of individuals mentioned in a report.

Availability

A copy of this policy is made available to officers and employees of Count:

  • www.count.au;
  • at Equity Partners Managing Principals’ and Chairs Conferences;
  • at staff briefing sessions; and
  • in employee induction information pack and training for new starters.

Related Policies

  • Count Code of Conduct
  • Count Respectful Workplace Behaviours
  • Work Health and Safety Policy
  • Count Grievance Policy