Whistleblower & speak-up

1. Purpose

HLD Group encourages reporting of suspected misconduct, fraud, safety issues, or policy violations without fear of retaliation, consistent with Australian whistleblower protections where applicable.

2. What to report

• Fraud, bribery, or financial misstatement
• Harassment, discrimination, or workplace violence
• Serious breaches of security or privacy policies
• Export control or sanctions violations
• Conduct that may harm customers, personnel, or the public

3. How to report

Reports may be made to your manager, HR, the CISO, or anonymously via the designated speak-up channel published internally. External disclosures to regulators are protected when made in good faith per applicable law.

4. Protection

Retaliation against reporters is grounds for disciplinary action. Identity is kept confidential to the extent possible while conducting a fair investigation.

5. Investigation

Reports are triaged, investigated by appropriate parties, and closed with documented outcomes. Unsubstantiated reports made in bad faith may be addressed separately.