Whistleblower & Grievance Policy

1 · Purpose

Nxt7a wants people to speak up about wrongdoing and to raise workplace concerns, and to do so safely. This policy sets out how disclosures and grievances are made, protected and handled. It combines two related but distinct routes: formal whistleblowing about serious misconduct, and everyday grievance resolution.

2 · Scope

The whistleblower protections apply to eligible whistleblowers as defined under the Corporations Act 2001 (Cth) – including current and former employees, officers, contractors and their relatives. The grievance process applies to all workers.

3 · Policy Statements

Whistleblowing

What can be reported. Disclosable matters include misconduct, or an improper state of affairs – for example dishonesty, fraud, corruption, breach of law, danger to health, safety or the environment, or concealment of any of these.

How to report. Disclosures can be made to an eligible recipient: [named eligible recipient(s) – e.g. CEO, a director, or an external service]. Disclosures may be made anonymously.

Protection. Eligible disclosures made on reasonable grounds are protected. Nxt7a will not tolerate any detriment, victimisation or retaliation against a person who makes, or is believed to have made, a disclosure. The whistleblower's identity is protected and will not be revealed without consent except as the law permits.

Handling. Disclosures are assessed promptly, investigated fairly and impartially, and the discloser kept informed so far as is appropriate while preserving confidentiality and fairness to anyone named.

Grievances

Everyday concerns – about treatment, decisions, working relationships or conditions – should first be raised informally with a manager where possible. If that is not appropriate or does not resolve the matter, a formal grievance may be raised with People & Culture or the CEO.

Process. Grievances are acknowledged, handled confidentially, investigated proportionately, and resolved as quickly as fairness allows. All parties are treated with respect and given a chance to be heard.

4 · Roles & Responsibilities

• Workers raise concerns honestly and on reasonable grounds.
• Eligible recipients / managers receive disclosures and grievances, protect confidentiality, and escalate appropriately.
• CEO / Company Secretary owns the policy and oversees serious investigations, engaging counsel where needed.

5 · Compliance, Monitoring & Breach

Causing detriment to a whistleblower, or breaching their confidentiality, is a serious breach of this policy and may breach the law. Such conduct will be addressed under the Code of Conduct and may be reported to authorities.

6 · Related Documents

Code of Conduct · DEI Policy · Employee Handbook · Anti-Bribery & Corruption Policy.

7 · Standards Mapping

• B Corp: Governance.
• ISO/IEC 27001: A.6 (People); supports A.5 reporting controls.
• Statutory (AU): Corporations Act 2001 (Cth) Part 9.4AAA whistleblower protections; Fair Work grievance principles.

Review note. Whether Nxt7a is required to have a compliant whistleblower policy depends on its company type; B Corp and good governance favour adopting one regardless. The Corporations Act sets specific content and protection requirements – have [COO or delegate] confirm compliance and name the eligible recipients before adoption.

8 · Version History