HORIZON CLARITY — COMPLAINTS AND WHISTLEBLOWING POLICY
Website version
Version 1.0 | April 2026 | Applies to: All clients, practitioners, and stakeholders
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Complaints and Whistleblowing Policy
Policy owner: Emma Drew, Principal, Horizon Clarity
Review cycle: Annual, or following any substantive complaint
Contact: privacy@horizonclarity.com.au
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1. Purpose
Horizon Clarity is committed to maintaining the highest standards of professional conduct, ethical practice, and transparency in all engagements. This policy establishes clear, accessible, and fair processes for raising concerns — whether about the quality of Horizon Clarity's work, the conduct of its principals or practitioners, or matters of broader ethical concern observed in the course of an engagement.
We take all complaints and disclosures seriously. No person who raises a concern in good faith will be disadvantaged as a result of doing so.
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2. Scope
This policy applies to:
- Clients and client representatives engaged with Horizon Clarity
- Practitioners and contractors working under Horizon Clarity agreements
- Any third party who has direct dealings with Horizon Clarity in a professional capacity
This policy covers two distinct processes: complaints about Horizon Clarity's services or conduct, and whistleblowing disclosures about serious concerns arising within client organisations or in the course of an engagement.
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3. Complaints about Horizon Clarity
3.1 What constitutes a complaint
A complaint is any expression of dissatisfaction about Horizon Clarity's services, conduct, processes, or outputs, including:
- Quality or accuracy of diagnostic findings or recommendations
- Professional conduct of a Horizon Clarity principal or practitioner
- Breach of confidentiality or privacy obligations
- Failure to meet agreed timelines or deliverables
- Billing disputes or concerns about fees
- Any other matter relating to the conduct of a Horizon Clarity engagement
3.2 How to raise a complaint
Complaints may be submitted in writing to privacy@horizonclarity.com.au. Complaints may also be raised verbally during the course of an engagement. Horizon Clarity will confirm the substance of any verbal complaint in writing to the complainant within 5 business days.
Complaints should include: the nature of the concern, the date(s) the issue arose, the names of any individuals involved, and the outcome the complainant is seeking. Supporting documentation may be attached.
3.3 Response process
Horizon Clarity will:
- Acknowledge receipt of a complaint within 2 business days
- Assess the complaint and investigate as appropriate within 10 business days
- Provide a written response to the complainant outlining findings and any action taken
- Where resolution is not possible within 10 business days, advise the complainant of expected timelines and reasons for delay
Where a complaint involves the Principal directly and cannot be resolved internally, the complainant may refer the matter to the relevant professional body or regulatory authority.
3.4 Confidentiality
All complaints will be handled with discretion. The identity of a complainant will not be disclosed beyond those directly involved in resolving the complaint, except where disclosure is required by law.
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4. Whistleblowing Disclosures
4.1 Purpose of this section
In the course of diagnostic engagements, Horizon Clarity staff may become aware of serious concerns within client organisations — including potential fraud, corruption, serious governance failures, harm to individuals, or breaches of legal obligations. This section establishes how such concerns will be managed.
Horizon Clarity also recognises that clients, practitioners, or third parties may wish to disclose concerns about matters they have observed in connection with a Horizon Clarity engagement. This policy provides a safe and confidential channel for such disclosures.
4.2 What can be disclosed
A whistleblowing disclosure may relate to:
- Suspected fraud, corruption, or financial misconduct within a client organisation
- Serious misrepresentation of information provided to Horizon Clarity during an engagement
- Harm or risk of harm to individuals, including staff, clients, or communities
- Significant governance failures or breaches of legal or regulatory obligations
- Conduct by a Horizon Clarity practitioner that raises serious ethical concerns
- Any other matter the discloser reasonably believes constitutes a serious risk
4.3 How to make a disclosure
Disclosures may be made confidentially in writing to privacy@horizonclarity.com.au, clearly marked as a whistleblowing disclosure. Anonymous disclosures are accepted, however Horizon Clarity's ability to investigate and respond may be limited where contact details are not provided.
Horizon Clarity will acknowledge receipt within 2 business days and confirm how the disclosure will be handled.
4.4 How disclosures are handled
Upon receiving a disclosure, Horizon Clarity will:
- Assess the nature and seriousness of the concern
- Determine whether the matter falls within Horizon Clarity's scope to address, or whether it requires referral to an external authority such as a regulator, law enforcement, or relevant oversight body
- Where the concern is assessed as serious, seek independent ethics guidance to inform its management
- Advise the discloser of the outcome of this assessment within 10 business days
- Where appropriate, incorporate the disclosure into the relevant diagnostic engagement findings
Horizon Clarity is not an investigative or regulatory authority. Where disclosures relate to matters requiring formal investigation, we will support the discloser in identifying the appropriate channel.
4.5 Protection for disclosers
Any person who makes a disclosure in good faith under this policy will not be subject to any form of retaliation, disadvantage, or adverse treatment by Horizon Clarity. This protection applies regardless of whether the disclosure is ultimately substantiated.
Where a discloser is an employee or contractor of a client organisation, Horizon Clarity will not share the identity of the discloser with that organisation without explicit consent, except where required by law.
4.6 Limits of this policy
This policy does not override the obligations of Horizon Clarity principals or practitioners under Australian law, including mandatory reporting obligations where these apply. Where a disclosure reveals an imminent risk of serious harm, Horizon Clarity reserves the right to notify relevant authorities.
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5. Record Keeping
Horizon Clarity will maintain a confidential register of all complaints and whistleblowing disclosures. Records will be retained for a minimum of 7 years in accordance with Horizon Clarity's data retention obligations. Records will be stored securely and accessible only to the Principal.
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6. Review
This policy will be reviewed annually, or sooner if a complaint or disclosure reveals a gap in the policy's coverage. Material changes will be communicated to active clients and practitioners.
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7. External Escalation
If a complainant or discloser is not satisfied with Horizon Clarity's response, or if the matter relates to conduct that falls outside Horizon Clarity's capacity to resolve, the following external bodies may be relevant:
Australian Securities and Investments Commission (ASIC) — Corporate governance, financial misconduct, director duties
Australian Human Rights Commission — Discrimination, harassment, human rights concerns
Office of the Australian Information Commissioner (OAIC) — Privacy breaches, data handling complaints
Fair Work Ombudsman — Employment-related concerns involving practitioners
Relevant state or federal police — Criminal conduct, fraud, serious harm
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Version 1.0 | April 2026 | © Horizon Clarity