Important Information | Whistleblower Policy
The Archdiocese of Melbourne through its financial activity known as the Catholic Development Fund (ABN: 15274 943 760), the CDF Community Fund (ABN 94 380 397 118), and CDFCF AFSL Ltd (ABN: 49 6229 767 47)(collectively known as “CDF”) seeks to provide the best possible service to its customers by providing account holders with an opportunity to invest in a fund that will be used to support the mission of the Church by providing low cost funding for Catholic capital building projects in Parishes, Parish Primary Schools, Catholic Colleges, Religious Orders, Diocesan Agencies, Catholic Church organisations, and in Health and Aged Care.
In addition, CDFCF AFSL Ltd as a holder of an Australian Financial Services Licence is responsible for ensuring that it complies, on an ongoing basis, with its obligations as a licensee (and for taking reasonable steps to ensure that its representatives comply with the financial services laws). This Policy describes CDF’s approach to addressing the requirements of the Corporations Act 2001 as amended (the Act).
The Act applies to CDFCF AFSL Ltd. Catholic Development Fund and the CDF Community Fund have determined that, except where specifically indicated in this Policy as only applying to CDFCF AFSL Limited, they will voluntarily apply the requirements of the Act.
CDF encourages a culture of raising concerns. CDF is committed to ensuring that any concerns can be raised in a safe and secure manner. The purpose of the Policy is to:
A person (Discloser) is a Whistleblower under this Policy and entitled to the protections in this Policy if they meet the criteria set out below.
A disclosure is a report of information made in the way set out in this Policy.
This Policy sets out:
A person making a disclosure (“you”) may be any of:

If you have any questions about this policy prior to making any disclosure, you can ask any of the Recipients listed below, in confidence, about the process for making a disclosure.
Identification
You may choose to remain anonymous or use a pseudonym when making a disclosure.
However, we may not be able to undertake a proper investigation if we cannot contact you to obtain further information. We therefore recommend that if you wish to remain anonymous you provide an anonymous email address, to allow ongoing two-way communication.
Persons to whom disclosure can be made:
To qualify for Whistleblower protection, disclosure must be made to any one of the following Recipients:
Internal Recipients
External Recipients
Appendix B contains their contact details.
A disclosure can be made by talking to one of these people, or in writing. You may make the disclosure outside business hours if necessary.
CDF encourages staff to make disclosures internally in the first instance.
Public Interest Disclosure and Emergency Disclosure
In respect of CDFCF AFSL Ltd only, disclosures can be made to a journalist or parliamentarian where:
In respect of CDFCF AFSL Ltd only an Emergency Disclosure may be made to a journalist or parliamentarian, where:
This Policy applies to disclosures of information where you have reasonable grounds to suspect:
Examples of disclosures include dishonest or unethical behaviour and practices, conduct that causes harm or conduct which does not met the expectations in the CDF Code of Conduct, such as:
As long as you have a reasonable belief that wrongdoing has occurred you will not be penalised if the disclosure turns out to be incorrect.

Disclosures which are not covered by the Policy include disclosures that:
If the disclosure is made to one of the internal contacts it will be escalated to the Whistleblower Investigation Officer (WIO). The WIO is the person holding the title General Counsel, Catholic Archdiocese of Melbourne. Where contact details for the Whistleblower are provided, the WIO will acknowledge receipt in a reasonable timescale.
The process that will be followed is:

CDFCF AFSL Ltd has a legal obligation to ensure legal protections are in place for Whistleblowers. Except where stated below, the CDF Board has agreed to extend these protections across the CDF organisation. In summary:
Confidentiality
CDF will keep your identity and information that is likely to lead to your identification confidential and will not disclose it to any person except:
CDF makes all reasonable efforts to ensure records relating to Disclosures are kept secure. This includes secure storage of confidential information and restricted access regarding disclosures.
If you are concerned that there has been a breach of confidentiality, you may lodge a complaint with CDF or a Regulator for investigation.
Detrimental acts or omissions
CDF will take all reasonable efforts to protect you from detriment in relation to a Disclosure. This includes protections regarding any threat to cause detriment to you in relation to the disclosure. Examples of detriment may include termination of your employment, alteration of your employment position to your disadvantage, bullying or harassment.
The WIO will work with you to ensure that appropriate arrangements are in place to protect you and assist your wellbeing.
Regarding CDF AFSL Ltd only:
(a) Compensation and other remedies
As a Whistleblower qualifying for protection under this Policy and the Act you can seek compensation and other remedies through the courts in relation to any Disclosure relating to CDFCF AFSL Ltd, if:
You may wish to seek your own legal advice regarding compensation.
(b) Civil, criminal and administrative liability protection
A Whistleblower qualifying for protection under this Policy and the Act regarding CDF AFSL Ltd is protected from the following:
in respect of the disclosure made by the Whistleblower. The above protections do not grant immunity for any misconduct undertaken by the Whistleblower which is revealed in their Disclosure.
The Policy is owned by the General Manager Finance, Risk & Administration (GM FRA), who is responsible for compliance assurance, communication and maintenance issues, including:
The GM FRA reviews the Policy at least every two years and more frequently if necessary.
The review will consider any changes to relevant laws, Australian standards for compliance, market and business conditions, the CDF’s procedures and systems and the Fund’s organisational structure.
The GM FRA will assess the CDF’s adherence to the provisions of the Whistleblower Policy at least every five years and provide a report to the Audit & Risk Management Committee (A&RMC).
This Policy was adopted by the CDF Board on 11 December 2020 and the CDFCF AFSL Ltd Board on 27 November 2020.
This Policy has unrestricted internal and public access. The approved Policy is available on the CDF and CDF Community Fund websites, along with the staff intranet site.
An eligible Whistleblower can make a Disclosure under the CDF Whistleblower Policy:
Internal Recipients:
Disclosures can also be made to the above recipients in person during standard business hours at 486 Albert Street, East Melbourne 3002,
or by mail to PO Box 174, East Melbourne VIC 8002.
Independent Recipient:
Whistleblower Investigations Officer:
CDPF Limited, a company established by the Australian Catholic Bishops Conference, has indemnified the Catholic Development Fund ABN 15 274 943 760 (the Fund) against any liability arising out of a claim by investors in the Fund. In practice, this means your investment is backed by the assets of the Catholic Archdiocese of Melbourne. The Fund is required by law to make the following disclosure. Investment in the Fund is only intended to attract investors whose primary purpose for making their investment is to support the charitable purposes of the Fund. Investors’ funds will be used to generate a return to the Fund that will be applied to further the charitable works of the Archdiocese of Melbourne and the Dioceses of Sale and Bunbury. The Fund is not prudentially supervised by the Australian Prudential Regulation Authority nor has it been examined or approved by the Australian Securities and Investments Commission (ASIC). An investor in the Fund will not receive the benefit of the financial claims scheme or the depositor protection provisions in the Banking Act 1959 (Cth). The investments that the Fund offers are not subject to the usual protections for investors under the Corporations Act (Cth) or regulation by ASIC. Investors may be unable to get some or all of their money back when the investor expects or at all and investments in the Fund are not comparable to investments with banks, finance companies or fund managers. The Fund’s identification statement may be viewed here or by contacting the Fund. The Fund does not hold an Australian Financial Services Licence.