Whistleblowing Policy

Scope of this policy

This policy extends to Flight Centre Travel Group Limited’s (FCTG) global business including Board members, employees, and contractors /agents / representatives (where relevant).

Background

FCTG is committed to developing a culture where all staff are encouraged to raise concerns about poor or unacceptable practice and misconduct, and can do so safely. The purpose of this policy is to promote responsible whistleblowing about issues where the interests of others, including the public, or of FCTG itself, are at risk. Such issues might include:

• Fraud
• Theft
• Harassment
• Workplace bullying
• Discrimination (sex, age, gender, race, religion etc)
• Bribery and corruption
• Manipulation or falsification of financial records

Responsibilities for all employees

Each employee is in a position of trust and should be adhering to the appropriate standards of ethical behaviour including compliance with applicable laws and regulations. Each employee is expected to make every effort to protect the interests of the company, including taking action to prevent the occurrence of inappropriate behaviour.

To the extent that an employee becomes aware of inappropriate behaviour as defined above, they should follow the below procedures.

Reporting concerns

If you have any known or suspected concerns regarding the appropriateness of someone’s conduct by way of:

• an unlawful act or omission;
• unethical behaviour; or
• any breach of a FCTG policy or procedure;

You should make a disclosure about it. Your responsibility is to report this concern to:

• Your team leader; or
• Their leader or someone in your reporting line such as area leader,
  nation leader, CFO, EGM or X-team member;
• Peopleworks;
• Enterprise Risk:
  Brett Anderson +61 407 392 084, brett_anderson@flightcentre.com;
  Sonya Ryan +61 401 060 012, sonya_ryan@flightcentre.com;
• Company Secretary:
  David Smith +61 404 856 317, david_smith@flightcentre.com;
• Chairman of the Audit Committee: Rob Baker, rbak3698@gmail.com

If you feel uncomfortable or unable to report your concern to these people, please call FCTG’s whistleblower line that is operated 24/7 by an independent third party, PricewaterhouseCoopers (PwC).

Below are free-call numbers:

• AUS: 1800 308 064
• NZ: 0800 854 249
• RSA: 0800 989 000
• India: 0800 610 1115
• UK: 0800 015 9714
• USA: 0855 522 8911
• China: 0800 261 1332
• HK: 800 903 702
• Canada:  1855 790 6901
• Dubai: 0800 0610 4387
• Singapore: 0800 616 7054
• Mexico: 1800 123 9560
• Malaysia: 1800 818 537
• Ireland: 1800 222 368
• Anywhere (non- freecall): +61 7 3257 8159

PwC will take your call, listen to your concern and decide an appropriate course of action.

Any disclosures will be investigated fully.  The whistleblower will be kept informed of the progress and the outcome of the investigation, within the constraints of maintaining confidentiality or observing legal restrictions generally.

Confidentiality

FCTG encourages individuals to put their name to concerns which they raise in case additional information is required further into the investigation. However, employees can raise their disclosure anonymously or ask PwC that their identity is not disclosed. Anonymous disclosures will be investigated to the extent they can be without revealing your identity.

If you make an anonymous disclosure you will be given a unique identifier number that you can quote in subsequent conversations with PwC. This will allow you to continue an ongoing dialogue with them as investigations progress.

Commitment to protecting employees

FCTG has appointed a Whistleblowing protection officer, a senior FCTG employee who has the responsibility of providing individual employees with protection against disadvantage.

Anonymity

FCTG is committed to protecting employees in making genuine disclosures and all reasonable efforts will be made to ensure that anonymous disclosures remain anonymous.  Anonymity cannot be guaranteed in certain circumstances (e.g., court orders).

Immunity from Disciplinary Action

If an allegation is made in good faith, but is not confirmed by the investigation, no action will be taken against the person raising the misconduct concern. If however, the allegation is or appears to be vexatious or frivolous, or without good reason, the same protection may not be provided.

Review of policy

This policy and the actions outlined above will be reviewed to ensure they are relevant and appropriate for our workplace.

Related policies and procedures

• Equal Employment Opportunity Policy
• Occupational health and Safety policies
• Finance policies
• Communications, Email and Internet policy

Endorsement

FCTG’s board and executive team is committed to this policy and its implementation and to ensuring an enjoyable and healthy and safe working environment.