At a Glance
All Five Good Friends Members, workers and stakeholders have the opportunity to provide feedback about their service and experience. We will make it easy for any person to provide feedback and base our approach on the principle, ‘Nothing about us without us’.
Five Good Friends is committed to an effective feedback and whistleblower system that supports improved outcomes and experience for individuals, and learning for the organisation. We will ensure that any feedback provided does not compromise the standard of care and support delivered to individuals making a complaint or providing feedback. No individual will experience victimisation, discrimination, or adverse treatment for providing genuine feedback.
When providing information under this policy, you can tell us if you would like it handled as a complaint, feedback, or whistleblowing disclosure.
Complaints and feedback will be handled in accordance with Section 1 of this policy.
Whistleblowing disclosures can be made if you think Five Good Friends has breached it’s obligations under the Aged Care Act, the NDIS Act, or the Corporations Act. You can make a whistleblowing disclosure by following the steps in Section 2 of this policy.
Individuals who make non-genuine, frivolous, or vexatious complaints and whistleblowing disclosures will not qualify for protections under this policy.
Scope
This policy relates to all Five Good Friends Members, their key supports, and all Five Good Friends workers, including Associates Providers workers.
Objective
The purpose of this policy is to provide our clear position on the management of feedback, complaints, and whistleblowing.
Definitions
- Aged care - includes the Support at Home Program and the Commonwealth Home Support Program
- Complaint – is an expression of dissatisfaction with a support or service provided by Five Good Friends.
- Disclosure - Personal information may only be shared with third parties upon obtaining explicit consent from the individual concerned. Refer to the Privacy Policy for more information.
- Feedback – any information provided to us related to any aspect of our organisation. We identify complaints, comments, compliments, and suggestions for improvement as types of feedback that can be provided.
- Key Personnel - People for NDIS providers who are responsible for executive decisions and responsible for, or have authority or significant influence over, planning, directing or controlling provider activities. At Five Good Friends, this includes Board Directors, the CEO and the Head of Care & Quality.
- NDIS - is the National Disability Insurance Scheme
- Natural Justice – is the right of all people to a fair and unbiased hearing.
- Open Disclosure – means having open discussion with our stakeholders and includes:
- identifying when things go wrong
- acknowledging and expressing regret
- providing support to those affected
- finding out and explaining what happened, and
- learning from the experience.
- Procedural Fairness – this means we undertake a fair and unbiased approach to managing feedback.
- Reasonable Grounds - this means that a reasonable person, based on the facts available, would have the same suspicion or belief. It is an objective legal standard that requires more than just a hunch or suspicion; there must be a solid and sound basis for the belief or action.
- Registered Supporter - is any person registered as a supporter under the Aged Care Act 2024 (Cth) to assist Members in understanding, making, and communicating decisions.
- Responsible Person - is an individual who has significant influence, oversight, or day-to-day management of a registered aged care provider's operations. At Five Good Friends, this includes Board Directors, the CEO, the Head of Care & Quality, and the Manager - Clinical & Complex Care.
- Whistleblower – is defined within the legislation and is outlined below in section 2 of this policy.
- Worker – employees, contractors, Helpers, Associates Providers personnel.
1. Feedback and complaints
How to give feedback to us or make a complaint
Any person can make or withdraw a complaint or give feedback to us about our supports and services:
Feedback management system
Five Good Friends will not charge any costs for making, withdrawing or managing a complaint or giving, withdrawing or managing feedback.
We will keep the information provided in a complaint or feedback confidential and only disclose it as required by law or if the disclosure is otherwise appropriate in the circumstances.
All complaints and feedback will be dealt with using the principles of natural justice, fairness and impartiality. We practice open disclosure and prioritise restorative practices.
Anonymous complaints or feedback can be made; however, our ability to investigate them may be limited.
We manage the complaints and feedback in accordance with our feedback management system.
Assistance available
Independent Aged Care Advocate
- The National Aged Care Advocacy Program (NACAP) provides free, confidential, and independent advocacy support to aged care consumers and their families
- NACAP is delivered by the Older Persons Advocacy Network (OPAN), with locations in each state and territory
- To find out more, visit the OPAN website or call 1800 700 600
Independent Disability Advocate
- If you need someone to support you or speak up for you, you can get help from an advocacy service which you can find here: https://askizzy.org.au/disability-advocacy-finder.
Interpreter
- If you need an interpreter, you can phone the Translating and Interpreting Service on 131 450 then ask for our number 1300 787 581
- Interpreters are available via phone and in person
National Relay Service
- If you are hearing or speech impaired you can contact us through the National Relay Service
- TTY users: phone 1800 555 677 then ask for our number 1300 787 581
- Speak and Listen users: phone 1800 555 727 then ask for our number 1300 787 581
- Internet relay users: go to https://nrschat.nrscall.gov.au/nrs/internetrelay and enter our number 1300 787 581
How we resolve complaints
We aim to resolve each issue raised in the complaint by taking appropriate action in relation to the issue as soon as practicable after receiving the complaint.
Our resolution approach:
- is consistent with the aged care Statement of Rights and the NDIS rights and responsibilities;
- takes into consideration the nature of the issue;
- considers each individual to whom we deliver services who is directly affected by the issue;
- keeps the relevant people informed of and involved in the resolution of the complaint;
- seeks to address the issue(s) raised in the complaint; and
- will contribute to the continuous improvement of our delivery of services.
We will tell you the outcome of the complaint and the reasons for the outcome. If the complaint was made by someone on your behalf, we will tell them and you the outcome of the complaint and the reasons for the outcome. If the complaint was made anonymously, we will not be able to communicate the outcome.
We will take reasonable steps to tell the relevant person the options for reviewing decisions related to the complaint and how the complaint may be made to the Aged Care Quality and Safety Commission or the NDIS Quality and Safeguards Commission.
How we respond to feedback
Unless the feedback was given anonymously, we will consult with the person who gave the feedback, the relevant individual, the individual's registered supporter, and the individual’s authorised representative (if any and with the individual's consent).
We will take reasonable steps to tell the relevant person how the feedback may also be given to the Aged Care Quality and Safety Commission or the NDIS Quality and Safeguards Commission.
No victimisation
We will take reasonable steps to ensure that the person who made a genuine complaint or gave the feedback, or on whose behalf the complaint was made or the feedback was given, is not adversely affected as a result of the making of the complaint or the giving of the feedback.
We will take reasonable steps to ensure that no individual to whom we deliver services who is affected by an issue raised in the complaint or feedback suffers any detriment, victimisation or reprisal as a result of the making of the complaint or the giving of the feedback.
How to make a complaint or give feedback to the Aged Care Quality and Safety Commission
You can contact the Aged Care Quality and Safety Commission to give feedback or make a complaint about our funded aged care services:
How to make a complaint or give feedback to the NDIS Quality and Safeguards Commission
You can contact the NDIS Quality and Safeguards Commission to give feedback or make a complaint about our supports and services
2. Whistleblowers
What is whistleblowing?
Aged Care
Where you disclose any information to us (in writing or verbally) and you have reasonable grounds to suspect that the information indicates that we may have breached the Aged Care Act.
To qualify for whistleblower protections under the Aged Care Act, you must have reasonable grounds to suspect a contravention of the Aged Care Act by Five Good Friends.
You can make a disclosure anonymously.
NDIS
Where you disclose any information to us (in writing or verbally) and you have reasonable grounds to suspect that the information indicates that we may have breached the NDIS Act.
To qualify for protection under the NDIS Act, the discloser must inform the person to whom the disclosure is made of their name, have reasonable grounds to suspect a contravention of the NDIS Act by Five Good Friends, and must make the disclosure in good faith.
Corporations Act
Where you disclose any information to us (in writing or verbally) and you have reasonable grounds to suspect Five Good Friends is engaging in misconduct or engaging in improper situations or circumstances. Individuals are encouraged to report if they witness or know about any behaviour that:
- Is fraudulent, corrupt, dishonest, or unethical
- Is illegal - including theft, dealing in or use of illicit drugs, violence or threatened violence and criminal damage against property
- Violates the law or any legal code, such as:
- the Corporations Act
- laws enforced by ASIC
- any other law of the Commonwealth
- Creates unsafe work practices or poses a serious risk to the health and safety of any person at the workplace
- Breaches any of Five Good Friends policies
- Discriminates
- Is harassment and/or bullying of any kind
- Is detrimental to Five Good Friends and could cause financial or non-financial loss.
Who can make a whistleblowing disclosure?
Aged Care
You can make a disclosure if you are:
- accessing funded aged care services (Member),
- a supporter of someone accessing funded aged care services,
- a responsible person,
- an aged care worker,
- an individual who becomes aware of information the disclosure of which would be protected under the Aged Care Act can make a disclosure.
NDIS
You can make a disclosure if you are:
- a participant (Member) who is receiving a support or service,
- a family member, carer or significant other of a participant who is a support or service,
- a current employee of Five Good Friends
- a supplier of goods or services to Five Good Friends.
Corporations Act
You can make a disclosure if you are an individual who is or has been:
- an officer, being a director or company secretary;
- an employee;
- an individual who supplies services or goods, or any employee of such an individual;
- an associate;
- a relative or dependant of an officer, director, company secretary or employee of Five Good Friends.
Who can I make a disclosure to?
Aged Care
You can make a whistleblowing disclosure to:
- the Aged Care Quality and Safety Commission (ACQSC) (including the Complaints Commissioner or a staff member of the ACQSC);
- the Department of Health, Disability and Ageing (Department) (including the System Governor, or an official of the Department);
- a registered provider (including us);
- a responsible person of a registered provider;
- an aged care worker of a registered provider;
- a police officer;
- an independent aged care advocate.
NDIS
You can make a whistleblowing disclosure to:
- the NDIS Quality and Safeguards Commission (NDISQSC) (including the Commissioner or a staff member of the NDISQSC);
- the National Disability Insurance Agency (NDIA) (including an official of the NDIA);
- a key personnel of Five Good Friends.
Corporations Act
You can make a whistleblowing disclosure to:
- a Board Director;
- Senior Managers
- a financial auditor, or a member of a financial audit team conducting an audit, of the Five Good Friends;
- a legal practitioner for the purpose of obtaining legal advice or legal representation;
- ASIC;
- APRA (though we are not in the business of superannuation and so the entity may not deal with the disclosure);
- a Commonwealth authority otherwise prescribed to receive disclosures
How to make a whistleblowing disclosure to us
Any person listed in above in Who can make a whistleblowing disclosure? can make a whistleblowing disclosure to us about our supports and services:
Workers (employees, Helpers, responsible persons/key personnel, and Associates Providers) who receive whistleblowing disclosures must report the disclosures through the Feedback Form.
How to make a whistleblowing disclosure to an external body
Disclosures made to any external bodies, including the NDIA, the Department, the NDISQSC, and ACQSC, may be made in accordance with the directions of that external body. This may include contacting them in writing through their website or calling them on their available numbers.
How will we investigate disclosures?
All disclosures will be treated seriously and, where appropriate, will be investigated in accordance with our workflows.
In carrying out our investigation, we will attempt to locate evidence to support any claims or allegations made in a whistleblowing disclosure.
How will we support whistleblowers and ensure their fair treatment?
We will support all whistleblowers while a disclosure is being investigated, including by:
- maintaining the confidentiality (and anonymity, where requested) of all whistleblowers, including by:
- redacting relevant information;
- referring to the whistleblower in a gender-neutral context;
- where possible, contacting the whistleblower to help identify certain aspects of their disclosure which may inadvertently identify them; and
- having disclosures handled by qualified and appropriate staff;
- assessing the immediate welfare and protection needs of any whistleblower;
- safeguarding the interests of a whistleblower in accordance with this policy and our obligations under the applicable legislation;
- addressing any issues or concerns of victimisation or threats of victimisation, including by:
- educating and training recipients of disclosures to ensure they can identify victimisation and threats of victimisation;
- taking action, including disciplinary action, against any recipients of disclosures (including staff) engaging in victimisation or threats of victimisation.
- Victimisation and threats of victimisation will not be tolerated.
Protection from liability
Under the Aged Care Act, NDIS Act, and Corporations Act, whistleblowers are protected from:
- any civil, criminal or administrative liability (including disciplinary action) for making a disclosure;
- any contractual or other kind of remedy being enforced or exercised against the whistleblower on the basis of the disclosure, including termination on the basis that disclosure constitutes breach of the contract.
Under the Corporations Act, protection from liability does not apply to disclosures that are considered frivolous or vexatious. If an investigation shows a disclosure was not made on objectively reasonable grounds, the whistleblower may not be protected, and disciplinary action, such as termination of employment, could be taken.
What to do if you have not been protected under this policy as a whistleblower?
Any whistleblowers who have a reasonable belief:
- that they are being victimised or threatened with victimisation as a result of any disclosure (or the belief or suspicion of a disclosure);
- that their confidentiality or anonymity has been breached under this policy; or
- that they have not been afforded any of the protections under this policy,
must report this behaviour to Five Good Friends.
Further information
If you require assistance in understanding this policy, please contact us on 1300 787 581.
If you require translation of this document in order to understand it, please use the accessibility widget available on the bottom, left-hand side of this page on the website.
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References and Related Documents
Five Good Friends
External
- Aged Care Act 2024 (Cth)
- Aged Care Rules 2025 (Cth)
- National Disability Insurance Scheme Act 2013 (Cth)
- Corporations Act 2001 (Cth)