Whistleblower Policy

While Mazda encourages individuals to report any concern they may have, not all types of concerns are covered by this Policy. The types of concerns that are generally not covered by this Policy are customer complaints and personal work-related grievances.

If you are a customer and have a complaint, please contact the relevant Mazda Dealership or Mazda Australia on 1800 034 411.

If you are an employee or contractor of Mazda Australia and wish to report a grievance that directly affects you personally in the context of your employment or wish to report any personal work-related grievance, you should contact a manager or HR.

1. Policy Definition

Mazda Australia (Mazda), as a subsidiary of Mazda Motor Corporation, is required to comply with a Corporate Law in Japan and the Financial Instrument and Exchange Law (JSOX), which enhances corporate internal control systems.

Further to this, as an Australian company, Mazda is required to comply with Part 9.4AAA of the Corporations Act 2001 (Corporations Act) and related provisions in the Taxation Administration Act 1953 (Taxation Administration Act), which provides a consolidated whistleblower protection regime for Australia’s corporate sector. The regime requires Mazda to have a whistleblower policy and make the policy available to those it is designed to protect.

2. Policy Overview

Mazda is committed to meeting its legal and ethical responsibilities. Part of Mazda’s compliance with the relevant laws requires the establishment of a formal disclosure management process to facilitate the safe, responsible and confidential reporting of incidents of unethical or serious adverse behaviour, harassment, fraud, corrupt conduct, questionable accounting or auditing matters from all sources internal to Mazda. 

This process enables a person to disclose information or concerns to the attention of management without fear of retribution. A discloser will not be disadvantaged or prejudiced as a result of making such a disclosure.

Mazda is committed to this process and would like to identify and address wrongdoing as early as possible. All reports that reach senior management will be investigated as appropriate.

3. Who Is An ‘Eligible Whistleblower’?

This policy applies to everyone who works at Mazda including managers, consultants, temporary employees, contract employees, full-time, part-time and casual employees.

For the purposes of Australian law, this policy also applies to all of the above workers regardless of whether they are current or former; to suppliers of services or goods to Mazda (whether unpaid or paid), including their employees; to associates of Mazda; and to relatives, dependants or spouses of any of the individuals mentioned above.

4. Reportable Matters

The following types of wrongdoing can be reported and qualify for protection if made by an eligible whistleblower:

  • Theft or stealing including the taking of property or things not belonging to that person including both the organisation’s property and another employee’s personal property
  • Fraud including the intentional deception, deliberately perpetrated, for profit or to gain some unfair or dishonest advantage including theft or stealing, trickery, breach of confidence, expression, omission, or concealment or any act calculated to deceive another
  • Other illegal conduct including drug sale/use, assault, violence or threatened violence or wilful or intentional damage to an organisation’s property
  • Secret Commission / Bribery including the receipt of payment or other bribe to forgo official act or correct processes or any offer accept a bribe
  • Inappropriate Financial Practice or Conduct including price fixing, overcharging, anti-competitive behaviour, price collusion, writing or conducting inappropriate business transactions or trading considered wrong or harmful to the organisation
  • Unethical Conduct including winning business under false pretences, inappropriate receiving of gifts to forgo correct processes, for example tendering etc.
  • Inappropriate Behaviour including unprofessional or unethical conduct
  • Financial irregularities
  • Failure to comply with, or breach of, legal or regulatory requirements
  • Detrimental conduct including engaging in or threatening to engage in detrimental conduct against a person who has made a disclosure or is believed or suspected to have made, or planning to make a disclosure
  • Public safety risks including information that indicates a significant risk to public safety.

A full list of disclosable matters is covered under the relevant laws Mazda is governed by (listed in paragraph 1 above).

If the type of wrongdoing is not covered by the policy (for example, relates solely to personal work-related grievances), you can raise the matter with your manager or HR in the usual manner. Examples of personal work-related grievances include personal conflicts between the discloser and another employee, decisions relating to the discloser’s terms or conditions of engagement or disciplinary action taken against the discloser for reasons unconnected with disclosures under this policy.

We strongly discourage deliberate false reporting including because it detracts from our ability to deal with legitimate reports of wrongdoing.

You will still qualify for protection even if the disclosure turns out to be incorrect.

5. How To Make A Disclosure

You can make disclosures that will receive management’s immediate attention and allow for disclosures to be made anonymously and confidentiality, securely and outside of business hours if preferred.

You may use the services of Your-Call, an outsourced provider. Your-Call will pass your concern directly to the Head of Finance and/or the Managing Director (or the Head of HR if the Head of Finance and the Managing Director are implicated in the disclosure) as appropriate. Disclosures can be reported securely, anonymously and confidentially.

There are three ways you can lodge reports with Your-Call:

i) Website: https://www.yourcall.com.au/mazda

You will be asked to supply your information on an electronic form which is confidential between you and Your-Call. Your identity and privacy will be protected. This service is available 24 hours a day, every day of the year.

ii) Telephone: 1300 790 228

Dial the telephone number above Monday to Friday between 7am and midnight AEST except public holidays and speak to a trained disclosure officer. You may remain anonymous if you wish.

iii) Letter: Locked Mail Bag 7777, Malvern Victoria 3144

You can post a report to the above address.

Whilst we encourage disclosures are made to Mazda in the first instance using the methods provided above, under the relevant laws in Australia you can also make disclosures to a lawyer; journalists and members of parliament (under certain circumstances); and to Australian Securities and Investments Commission (ASIC), the Australian Federal Police or the Australian Taxation Office (ATO) (if the matter relates to the tax affairs of Mazda) directly.

If you wish to seek additional information before formally making your disclosure, you can obtain additional information by contacting any of Mazda’s eligible recipients or an independent legal advisor.

6. Measures And Mechanisms For Protecting Anonymity When Making A Disclosure

Disclosures can be made anonymously and still be protected. Methods of making an anonymous disclosure are outlined above and the methods for protecting anonymity include the availability of anonymous telephone hotlines and email addresses and your ability to adopt a pseudonym if you prefer.

You can choose to remain anonymous throughout the whole process, including when making the disclosure, over the course of the investigation and after the investigation is finalised. You can refuse to answer questions that you feel could reveal your identity at any time, including during follow-up conversations. If you wish to remain anonymous we suggest that you maintain ongoing two-way communication to enable follow-up questions or provide feedback.

7. Protected Disclosures Concerning Tax Affairs

Disclosures by eligible whistleblowers concerning tax affairs (as protected under the Taxation Administration Act) will be protected where the disclosure is made to any of:

  • the Commissioner of Taxation;
  • an auditor (or member of an audit team) conducting an audit of Mazda; 
  • a registered tax agent or Business Activity Statement (BAS) agent who provides services to Mazda;
  • an officer or senior manager of Mazda; or
  • any other employee or officer of Mazda who has functions relating to its tax affairs, and
  • the discloser considers that the information may assist that recipient to perform their functions or duties under a taxation law in relation to Mazda or its associates; and
  • where the disclosure is made other than to the Commissioner of Taxation, the discloser has reasonable grounds to suspect that the disclosure indicates misconduct, or an improper state of affairs or circumstances, in relation to the tax affairs of Mazda or its associates.

A disclosure of tax affairs that meet this criteria will have the same protections set out at paragraph 6 of this policy.

8. Legal Protections For Disclosers

Confidentiality of your identity

It is an offence for a person to disclose the identity of the whistleblower, or information that is likely to lead to the identification of the whistleblower, without the whistleblower’s consent, where that person has obtained the information directly or indirectly because of a protected disclosure.

This does not apply to disclosures to ASIC, a member of the Australian Federal Police or a legal practitioner. Mazda may also disclose certain information which may lead to the identification of a whistleblower where reasonably necessary for the purposes of an investigation, in which case Mazda will take all reasonable steps to reduce the risk of identification.

Prohibition against adverse treatment and victimisation

Eligible whistleblowers must not be subject to any civil, criminal or administrative liability, or have any contractual or other right or remedy exercised against them, on the basis that they have made a protected disclosure.

It is also an offence to cause, or threaten to cause, detriment to a person due entirely or in part to a belief or suspicion that they (or any other person) have made, are proposing to make, or could make, a protected disclosure.

Detriment includes, without limitation, dismissal, injury in employment, harassment, intimidation and physical harm to a person or their property.

For example: It is unlawful for an employer to threaten an employee with dismissal if they make a protected disclosure.

Further, where a person makes a disclosure to ASIC, the Commissioner of Taxation (in relation to tax affairs) or makes a what is referred to in the Corporations Act as a “Public Interest” or “Emergency Disclosure”, the information disclosed is not admissible in evidence against that person in criminal proceedings or in proceedings for the imposition of a penalty, other than proceedings in respect of the falsity of the information.

9. How Mazda Will Protect Whistleblowers

Mazda will support whistleblowers and protect you from detriment in the following ways:

Protection from detrimental conduct

You will not be subject to any disciplinary or other detrimental action by Mazda by reason of your protected disclosure.

This includes (but is not limited to) protection from:

  • termination of employment
  • disciplinary action
  • performance management
  • bullying or harassment, or
  • unlawful discrimination.

We will ensure no person on its behalf victimises or threatens detrimental action against a person because you make a protected disclosure.

Protection of the identity of the whistleblower

Except in the circumstances specified below, Mazda will not disclose your identity as a whistleblower or any information that is likely to lead to the identification of you, unless you agree.

The circumstances in which Mazda may disclose this information are where disclosure is made:

  • to ASIC, Australian Federal Police or to a Commonwealth, State or Territory authority, for the purpose of assisting the authority in the performance of its functions;
  • to a legal practitioner; and/or
  • because it is reasonably necessary to do so for the purposes of Mazda investigating a matter to which the protected disclosure relates (in which case Mazda will ensure the disclosure does not identify you and will take all reasonable steps to reduce the risk you will be identified as a result of the disclosure).

Protection of files and records

All files and records created from an investigation will be securely retained.

Additional Support

Mazda recognises that making a disclosure as a whistleblower can be stressful. If you make a disclosure and you are a current employee of Mazda, you should contact our EAP provider) and may also request additional support.

While Mazda may not be able to provide the same level of counselling support to you if you are not a current employee, we will look at ways to provide support to the extent reasonably possible.

10. Investigation of disclosures by Mazda

Mazda will investigate all protected disclosures made under this policy, as appropriate, as soon as reasonably practicable after the disclosure is made. Mazda’s Whistleblowing Officer may, with the consent of the whistleblower, appoint a person/(s) to assist in the investigation.

The investigation will be conducted independently of any person who is the subject of the protected disclosure. Where appropriate, such persons will be informed of the allegations and provided with the opportunity to respond.

The investigation process will be determined by the nature and substance of the disclosure. If the disclosure is not anonymous, the Whistleblowing Officer or investigator will contact the whistleblower as soon as practicable upon receipt of the disclosure to discuss the investigation process, including who may be contacted and other matters relevant to the investigation.

Where appropriate, Mazda will provide feedback to the whistleblower regarding the progress and/or outcome of the investigation.

Where a report is submitted anonymously, Mazda will conduct the investigation based on the information provided to it.

Any findings of the investigation related to criminal activity will be reported to the police and/or regulators as appropriate.

11. How Mazda will ensure the fair treatment of individuals mentioned in a disclosure

Mazda will ensure that individuals mentioned in a disclosure, including those who are the subject of a disclosure by doing as follows:

  • Handling disclosures confidentially, where it is practical and appropriate in the circumstances;
  • Ensuring the objective of any investigation is to determine whether there is enough evidence to substantiate or refute the matters reported;
  • Ensuring the persons conducting the investigation are independent; and
  • Providing appropriate support services for employees that are mentioned or subject of a disclosure.
12. Access to Policy
  • Mazda will ensure that this policy is widely accessible by posting the policy on the internet.

 

Last updated:28 March 2025