Whistle Blower Policy

Legg Mason Asset Management Australia Limited
ABN 76 004 835 849

The Legg Mason Asset Management Australia Limited (Legg Mason Australia) Whistle blower Policy (Policy) has been established as per the ASIC Whistleblower Policies Regulatory Guide 270 and the relevant sections of the Corporations Act. This Policy ensures any Eligible Whistleblower who makes a disclosure of Disclosable Matters (“Whistleblowers”) can voice their concerns regarding any misconduct, improper state of affair or circumstances in relation to Legg Mason Australia without being subject to persecution, provocation or prejudiced treatment.

Here at Legg Mason Australia (LMA) we strive to achieve a high level of ethical standards in order to accomplish our corporate goals, uphold our corporate philosophy and maintain our strong reputation. We are committed to creating a safe, healthy and open work environment. 

We have an obligation to act in the best interests of LMA along with our employees, investors, and shareholders. We aim to protect these interests by highlighting potentially illegal or unethical activities. Our Board does not tolerate anyone being discouraged, disadvantaged or victimised from speaking up.

The purpose of this Policy is to: deter wrongdoing; encourage disclosures of wrongdoing; ensure all Whistleblowers disclosures are processed appropriately, timely and with the confidence that they may do safely; provide transparency around LMA’s framework for receiving, handling and investigating disclosures; support our values, code of conduct and ethics policy; uphold LMA’s long-term sustainability and reputation and; abide by LMA’s legal and regulatory obligations.

This Policy applies to any individuals who are, or have been, any of the following in relation to LMA: an officer or employee; a supplier of services or goods (including their employees); an associate; and/or a relative, dependant or spouse of an individual mentioned above.

This Policy applies to matters of misconduct in relation to LMA or our affiliates. These matters include, but are not limited to conduct involving: illegal activity; fraud, money laundering and/or misappropriation of funds; bribery; financial irregularities; failure to comply with, or breach of, legal and/or regulatory requirements and; engaging in or threatening to engage in detrimental conduct against a Whistleblower, a potential Whistleblower or a person suspected of being a Whistleblower.

Matters do not need to be illegal or unlawful in order to be reported, it may be a matter that relates to systemic issues; consumer harm; significant risk to public safety or the; stability and confidence of LMA. It is important to note that any and all Whistleblowers still qualify for protection even if the information disclosed is proved incorrect, provided the Whistleblower has reasonable grounds for their suspicion.

There are legal protections in place to protect Whistleblowers or any persons from detriment in relation to a disclosure. This means no persons can make threats or cause detriment to a Whistleblower in relation to their disclosure.

If you wish to make a disclosure you may do so externally by contacting a reporting body such as ASIC, APRA or AFP. However we urge all Disclosers to contact LMA at first instance.

Alternatively, you can report any incident internally by contacting our Whistleblowing Officer, Farhaana Desai at fdesai@leggmason.com . She can assist with any queries or concerns surrounding the Policy and the disclosure process.

It is important to note that internal and external Whistleblowers can choose to remain anonymous while making a disclosure, over the course of the investigation and after the investigation is finalised.