Protected Disclosure (Whistleblower) Policy

Effective Date: March 21, 2025
Website: www.initforce.com

1. Purpose

At Initforce, we’re committed to acting with integrity, transparency, and accountability in everything we do — especially in how we deliver Salesforce solutions to clients and engage with our team, partners, and community.

This Protected Disclosure Policy provides a safe and confidential way for individuals to report serious concerns — known as Reportable Conduct — without fear of retaliation or unfair treatment.

We encourage anyone connected to Initforce who sees something wrong, unethical, illegal, or dangerous to speak up.

2. Who This Policy Applies To

This policy applies to current and former:

  • Employees, contractors, interns, and freelancers
  • Salesforce consultants and delivery partners
  • Vendors, advisors, and service providers
  • Any individuals who work with or for Initforce
  • Their immediate family members or dependents

3. What You Can Report

You may make a protected disclosure under this policy if you have reasonable grounds to suspect any of the following types of Reportable Conduct related to Initforce or our partners:

  • Fraud, theft, or corruption
  • Unlawful, criminal, or unethical conduct
  • Serious misuse of company resources
  • Breach of client trust or Salesforce-related data misuse
  • Breach of our Code of Conduct
  • Health and safety risks
  • Environmental harm
  • Harassment, bullying, or discrimination
  • Modern slavery or human rights violations
  • Mismanagement by someone in authority

Disclosures made in good faith will be protected — even if they turn out to be incorrect.

4. What’s Not Covered

This policy does not cover personal employment grievances, such as disagreements with a manager or concerns about your pay — unless those issues also involve serious misconduct or unlawful behaviour. For HR-related matters, please speak with your Initforce contact or HR representative.

5. How to Make a Disclosure

You can make a disclosure by contacting our Whistleblower Protection Officer:

📧 whistleblower@initforce.com
🌐 Or via www.initforce.com/contact

If you don’t feel comfortable reporting internally, you may also contact:

  • A regulatory authority (e.g. NZ Ombudsman, ASIC, APRA)
  • An independent lawyer
  • A journalist or Member of Parliament (in limited emergency/public interest cases under NZ or AU law – see Appendix 1 & 2)

6. Can I Remain Anonymous?

Yes. You can report anonymously. However, doing so may limit our ability to follow up or conduct a thorough investigation. If you choose to identify yourself, your details will be kept confidential and only shared where legally required or with your consent.

7. Investigation Process

Once a report is received:

  • We will acknowledge your disclosure within 5 working days
  • A Whistleblower Protection Officer (or external investigator) will assess and, if warranted, investigate the issue
  • If you have shared your identity, we will keep you updated on progress where possible
  • The investigation will be handled impartially, confidentially, and fairly

We aim to complete investigations within 20 working days, or communicate otherwise if more time is required.

(See Appendix 3 below for a full investigation overview.)

8. Protection from Retaliation

Initforce will not tolerate any form of Detrimental Conduct or retaliation against whistleblowers. This includes:

  • Dismissal, demotion, or job discrimination
  • Harassment or threats
  • Any harm to your reputation, finances, or personal well-being

If you feel you are being treated unfairly for speaking up, report it immediately to our Whistleblower Officer.

9. Confidentiality

We treat all disclosures seriously and protect your confidentiality wherever possible. Your identity will only be revealed if:

  • You give consent
  • It is legally required
  • It’s necessary to ensure natural justice or prevent harm (we will consult you first, if applicable)

10. Support Available

If you’re an Initforce employee, you may access our Employee Assistance Program (EAP) for counselling and support. External whistleblowers may request appropriate support or guidance through our disclosure channels.

11. Consequences of Breach

Any retaliation, cover-up, or failure to comply with this policy will be treated seriously and may result in disciplinary action, including termination or legal consequences.

Appendix 1: Public Interest & Emergency Disclosures (Australia Only)

You may report to a journalist or MP only if:

  • You have already reported the concern to a regulator like ASIC or APRA
  • At least 90 days have passed without meaningful action
  • You believe further disclosure is in the public interest or involves an emergency
  • You’ve informed the regulator of your intent to disclose

Appendix 2: Appropriate Authorities (New Zealand Only)

In NZ, disclosures may be made to:

  • The Ombudsman or Inspector-General of Intelligence and Security
  • A regulator listed under the Protected Disclosures Act 2022
  • Any relevant public body with the legal authority to investigate

(Refer to the full list at legislation.govt.nz or contact us for guidance.)

Appendix 3: What to Expect After Disclosure

Within 20 working days, we aim to:

  1. Acknowledge receipt of your report
  2. Determine whether it warrants investigation
  3. Check if it has been reported elsewhere
  4. Take appropriate action (investigation, referral, or no further action)
  5. Provide feedback and reasons for the outcome, where possible

Questions?

If you’re unsure about anything in this policy or want to discuss a potential issue, contact:

📧 whistleblower@initforce.com