GOVERNANCE

Whistleblower Policy

How to raise a concern about misconduct at Owl Watch Services, what happens after you do, and the protection you have when you do it.

1. Purpose

Jafri Corporation Pty Ltd, ABN 43 614 703 294, trading as Owl Watch Security Services (“Owl Watch”) is committed to maintaining the highest standards of ethical conduct, integrity, and compliance with all applicable laws and regulations. This Whistleblower Policy establishes a framework for reporting and addressing concerns regarding suspected misconduct, unethical behaviour, or legal and regulatory breaches within the organisation.

This policy ensures that individuals can report concerns without fear of retaliation and that all reports are handled promptly, fairly, and confidentially where appropriate.

2. Scope

This policy applies to all directors, officers, employees, contractors, and volunteers of Owl Watch.

3. Reporting Responsibility

All personnel have a responsibility to report in good faith any concerns regarding:

  • Violations of Owl Watch policies or code of conduct
  • Suspected fraud, corruption, or unethical conduct
  • Breaches of applicable laws or regulations
  • Improper accounting, internal controls, or auditing practices

Failure to report known or suspected misconduct may itself constitute a breach of company policy.

4. How to make a report

You can raise a concern with your immediate supervisor first if you are comfortable doing so. Where that is not appropriate, or where you would rather report confidentially, use one of the channels below.

By email. Send your report to info@owlwatchservices.com with “Confidential, whistleblower report” in the subject line. Email marked this way is passed unopened to a director of the company.

By post. Mark your envelope “Confidential, addressed to a director” and send it to Owl Watch Services, 4/49 Heathcote Road, Moorebank NSW 2170.

You may make a report anonymously. If you do, please give us enough detail to investigate, since we will not be able to come back to you for more.

5. How reports are handled

The Whistleblower Contact is responsible for:

  • Receiving and documenting all whistleblower reports
  • Conducting or coordinating impartial investigations
  • Ensuring appropriate resolution of reported matters
  • Reporting findings to the General Manager and Managing Director
  • Providing periodic compliance updates to the an independent adviser

Where matters relate to accounting or auditing, the Whistleblower Contact will immediately escalate such issues to the an independent adviser.

6. Investigation Process

Upon receipt of a complaint, the Whistleblower Contact will:

  • Acknowledge receipt of the report where possible
  • Assess and initiate a timely investigation
  • Maintain confidentiality to the extent practicable
  • Determine findings based on available evidence
  • Recommend and implement corrective or disciplinary actions where appropriate

All investigations will be conducted fairly, objectively, and in accordance with procedural fairness principles.

7. Protection Against Retaliation

Owl Watch strictly prohibits retaliation against any individual who reports concerns in good faith or participates in an investigation.

Any employee found to have engaged in retaliation will be subject to disciplinary action, which may include termination of employment.

8. Good Faith Reporting

Reports must be made in good faith, based on reasonable grounds. Any deliberately false, misleading, or malicious allegations may result in disciplinary action.

9. Confidentiality

Owl Watch will treat all whistleblower reports as confidential to the extent possible, consistent with the need to investigate and resolve the matter effectively. Disclosure of information will be limited to individuals directly involved in the investigation and resolution process.

10. Policy Administration

This policy is overseen by senior management and reviewed periodically to ensure ongoing compliance with legal and regulatory requirements and organisational best practice.

Hasnain Jafri
Managing Director
Owl Watch Security Services