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Whistleblower policy
Bunnings is committed to the highest standards of conduct and ethical behaviour in all of our business activities and to promoting and supporting a culture of honest and ethical behaviour, corporate compliance and good corporate governance.
Bunnings encourages the reporting of any instances of suspected unethical, illegal, fraudulent or undesirable conduct involving Bunnings.
Bunnings provides protections and measures so that those persons who make a report may do so confidentially and without fear of intimidation, disadvantage or reprisal.
This policy is available on the Bunnings intranet and internet pages.
Who is an eligible whistleblower under this policy?
This policy applies to protected disclosures made in New Zealand by:
- an officer, former officer, team member, former team member, contractor, or former contractor of Bunnings
- an individual, or employee of a person or entity, who supplies goods or services to Bunnings
- an employee of a person or entity who supplies goods or services to Bunnings (whether paid or unpaid)
- an associate of Bunnings (meaning a director or secretary of Bunnings or of its related bodies corporate, or a person acting in concert with Bunnings); and
- a relative or dependant of any of the persons listed above.
What is "Reportable Conduct"?
You may make a report under this policy if you have reasonable grounds to suspect any misconduct or improper state of affairs or circumstances (Reportable Conduct). For example (noting that the following is not an exhaustive list), this might include having reasonable grounds to suspect that a Bunnings director, officer, team member, contractor, supplier, tenderer or other person who has business dealings with Bunnings has engaged in which:
- is dishonest, fraudulent or corrupt, including bribery or other activity in breach of the Wesfarmers Anti-bribery Policy;
- is illegal activity (such as theft, violence, harassment or intimidation, criminal damage to property, breach of competition and consumer law, breach of privacy law or other breaches of law);
- is unethical or in breach of Bunnings’ policies (such as dishonestly altering company records or data, adopting questionable accounting practices or wilfully breaching Wesfarmers’ Code of Conduct or Bunnings’ other policies or procedures);
- is potentially damaging to Bunnings, a Bunnings team member or a third party, such as unsafe work practices, environmental damage, health risks or abuse of Bunnings' property or resources;
- amounts to an abuse of authority or gross negligence or mismanagement by public officials;
- may cause financial loss to Bunnings or damage its reputation or be otherwise detrimental to Bunnings’ interests; or
- involves serious wrongdoing in Bunnings or by Bunnings, any criminal offences or any act or omission or course of conduct that constitutes a serious risk to public health or safety or the environment
- involves harassment, discrimination victimisation or bullying, that is systemic or widespread and is not characterised as personal work-related grievance;
- involves threats (expressly or impliedly) to take any retaliatory action against another person, where such action is taken against that person because they have made or may make a disclosure that qualifies for protection under this Policy or because they provide voluntary supporting information. Retaliatory action includes any victimisation, bullying, discrimination or harassment, whether against a Bunnings team member or another person; or
- involves any other kind of misconduct or an improper state of affairs or circumstances.
Bunnings expects that reports made under this policy are made honestly, ethically an on reasonable grounds. Persons making reports under this policy may still qualify for protection under this policy even if their disclosure turns out to be incorrect.
What is not Reportable Conduct?
Reportable Conduct generally does not include conduct concerning a person’s individual employment or former employment (other than as set out in Reportable Conduct). These matters, known as personal work -related grievances may include:
- an interpersonal conflict at work;
- a decision relating to engagement, transfer or promotion;
- a decision relating to terms and conditions of engagement; or
- a decision to suspend or terminate the engagement or to discipline the person.
These matters will typically be assessed and, where appropriate, investigated or addressed under Bunnings’ Respectful Workplaces Policy
Who can I make a report to?
Bunnings has several channels for making a report if you become aware of any issue or behaviour which you consider to be Reportable Conduct:
| Method | <pDetails |
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To Speak Up (independent third-party) |
A report may be made via the Bunnings Speak Up Service: a free external hotline and reporting service independently monitored by Deloitte. Speak Up reporting options are:
Reports may be made anonymously, Any details which may identify you (such as your name or contact details) will only be provided to Bunnings if you consent to those details being shared with Bunnings |
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To a Protected Disclosure Officer |
In order to ensure appropriate escalation if a disclosure is made internally, and timely investigation, we request that reports are made to any one of our Protected Disclosure Officers, listed below: Damian Zahra - Chief People Officer Judd Young – General Manager of Workplace Relations and Workforce Planning Workplace Relations Lawyers Michelle Curran – General Manager, Group Risk and Compliance Sophie Robinson – Risk and Resilience Manager Laura Gaspert - Head of Group Sourcing Compliance Mark Philips – State Investigations Manager |
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By post |
Reports may also be posted to c/- Locked Bag 3004, Hawthorn, Victoria, Australia, 3122 (marked Private & Confidential and to the attention of one of the Protected Disclosure Officers). |
In order to qualify for protection, a report must concern Reportable Conduct and be made by an eligible whistleblower to an eligible recipient identified in this policy, or any other recipient prescribed by law, such as an “officer” or “senior manager” of the company (includes a director, or a senior manager in the company who makes, or participates in making, decisions that affect the whole, or a substantial part, of the business of the company, or who has the capacity to affect significantly the company’s financial standing), the relevant regulator. Reportable Conduct will not be protected if the disclosing party:
- knows the allegations to be false or acts in bad faith; or
- discloses information protected by legal professional privilege.
Bunnings' investigation of Reportable Conduct
Bunnings will investigate Reportable Conduct reported under this policy as soon as practicable after the matter has been reported. Speak Up, or a Protected Disclosure Officer may, with your consent, appoint a person to assist in the investigation of a report. Where appropriate, Bunnings will provide feedback to you regarding the investigation’s progress and/or outcome (subject to considerations of the privacy of those against whom allegations are made).
Any investigation will be conducted in an objective and fair manner, and otherwise as is reasonable and appropriate having regard to the nature of the Reportable Conduct and the circumstances.
While the particular investigation process and enquiries adopted will be determined by the nature and substance of the report, in general, as soon as practicable upon receipt of the report, if the report is not anonymous, a Protected Disclosure Officer or delegate will contact you to discuss the investigation process, including who may be contacted and such other matters as are relevant to the investigation.
Where a report is submitted anonymously, Bunnings may conduct an investigation based on the information provided to it.
Protection of Whistleblowers
Bunnings is committed to ensuring confidentiality in respect of all matters raised under this policy, and that those who make a report are treated fairly and do not suffer retaliatory action.
(a) Protection against detrimental conduct
Retaliatory action includes dismissal, demotion, harassment, discrimination, disciplinary action, bias, threats injury to a person (including psychological harm, and/or damage to a person’s property or reputation, or their business or financial position or other unfavourable treatment connected with making a report.
If you are subjected to retaliatory action as a result of making or intending to make, a report under this policy you should:
- inform a Protected Disclosure Officer, officer of Bunnings immediately; or
- make a separate report about the threatened or actual retaliatory action in accordance with this policy.
Bunnings will not tolerate whistleblowers suffering threats of any retaliatory action or actual retaliatory action as a result of making a disclosure or report or because they may make a disclosure or report under this Policy and any such actions taken may result in disciplinary action up to and including termination of employment.
(b) Protection of your identity and confidentiality
Subject to compliance with legal requirements, upon receiving a report under this policy, Bunnings will take reasonable steps to keep your identity confidential and reduce the risk of disclosure in the course of an investigation and will only share your identity as a whistleblower or information likely to reveal your identity if:
- you consent in writing;
- the person who has acquired knowledge of the protected report reasonably believes that the disclosure of identifying information is essential to the effective investigation of the allegations in the report or to prevent serious risk to public health or safety or the environment or is essential having regards to the principles of natural justice; or
- the concern is raised with a lawyer for the purpose of obtaining legal advice or representation.
If Bunnings needs to investigate a report, it may disclose information that could lead to your identification, but it will take reasonable steps to reduce this risk.
Any disclosures of your identity or information likely to reveal your identity will only be made to an employee, advisor or contractor of Bunnings Group Limited, Bunnings Limited, or Wesfarmers Limited, who reasonably has a need to investigate, report on, or respond to, the matters raised in your disclosure.
(c) Protection of files and records
All files and records created from an investigation will be retained securely.
Unauthorised release of information to someone not involved in the investigation (other than senior managers or directors who need to know to take appropriate action, or for corporate governance purposes) without your consent as a whistleblower will be a breach of this policy.
Whistleblowers are assured that a release of information in breach of this policy will be regarded as a serious matter and will be dealt with under Bunnings; disciplinary procedures.
Persons considering making, or who have made disclosures can also seek further advice from Ombudsmen for advice. The contact details are as follows:
The Ombudsman
PO Box 10152
Wellington 6143
Phone: 0800 802 602
Email: info@ombudsman.parliament.nz
Web: www.ombudsman.parliament.nz
Duties of team members in relation to Reportable Conduct
It is expected that Bunnings’ team members who become aware of actual Reportable Conduct, or suspect on reasonable grounds, potential cases of Reportable Conduct, will make a report under this policy or under other applicable policies.
Reporting procedures
Protected Disclosure Officers will report to the Bunnings and Wesfarmers boards on the number and type of whistleblower incident reports annually, to enable Wesfarmers to address any issues at a divisional/business unit and/or Group level. These reports will be made on a ‘no names’ basis, maintaining the confidentiality of matters raised under this policy.
The Wesfarmers Audit and Risk Committee will receive copies of all Bunnings whistleblower reports, and whistleblower reports from Protected Disclosure Officers (as appropriate). In addition, serious and/or material Reportable Conduct will be considered by the Protected Disclosure Officers for immediate referral to the Chairman of the Wesfarmers Audit and Risk Committee.
Operation and Amendment of this policy
This policy:
- operates in addition to the Wesfarmers Whistleblower Policy and, in the event of any inconsistency with the Wesfarmers Whistleblower policy, the Wesfarmers Whistleblower policy will prevail to the extent of the inconsistency;
- cannot be amended without approval of the Bunnings Board. It will be reviewed from time to time to ensure that it remains effective and meets best practice standards and the needs of Bunnings.
Last amended 1 JULY 2025