Whistleblower and Ethics Policy

Aperim Pty Ltd (ABN 46150699737; ACN 150699737) is incorporated in New South Wales, Australia and operates the aicial brand. In this policy, “aicial” refers to that brand; “we”, “us” and “our” refer to Aperim Pty Ltd; and “you” refers to anyone raising, or considering raising, a concern under this policy, including an employee, contractor, customer or member of the public.

We want anyone connected to aicial, or affected by it, to be able to raise a genuine concern about unlawful, unethical, unsafe or improper conduct connected to aicial, without fear of retaliation. This policy explains what you can report, how to report it, the protection available to you, and what happens after you make a report.

This policy applies to conduct connected to aicial’s business, our services, and our website and waitlist, including the conduct of our employees, contractors and service providers. It applies whether or not you have any ongoing relationship with us.

You can report:

• a breach, or suspected breach, of a law that applies to aicial;
• a breach of one of the policies we publish, including the Ethics Charter commitments set out in our Terms of Service and reflected in our Responsible AI Usage Policy;
• a danger, or potential danger, to health or safety;
• financial impropriety, fraud or other dishonest conduct; and
• conduct that seriously risks aicial’s reputation or the trust our Ethics Charter is built on, even where it does not clearly breach a specific law or policy.

This policy is not the right channel for a personal workplace grievance that does not raise a concern of the kind listed above; raise that directly with the person you work with at aicial instead. If you are unsure whether your concern fits, report it anyway and let us make that assessment — we would rather review a report that turns out not to qualify than have a genuine concern go unreported.

Email ethics@aicial.com. Tell us as much as you reasonably can — what happened, when, who was involved, and any supporting information — so we can assess and, where appropriate, investigate the concern. You do not need to be certain that something has gone wrong; a genuine, honestly held concern is enough. If you have already raised the same concern with compliance@aicial.com, it is covered by this policy too — you do not need to send it twice.

You may report anonymously. Because email is our only reporting channel today, an email discloses the address it was sent from — if you want to report anonymously, use an email account that does not identify you, and avoid including details that would identify you indirectly. Reporting anonymously can limit our ability to investigate a concern fully or to update you on its outcome, so we encourage you to identify yourself if you are comfortable doing so.

If you identify yourself, we protect your identity to the extent legally possible and reasonably practicable for a company our size, disclosing it only to the people who need it to assess or investigate your report, or where disclosure is required by law. Where your disclosure qualifies for protection under Part 9.4AAA of the Corporations Act 2001 (Cth), that protection is stricter: we will not disclose your identity, or information likely to identify you, except with your consent, to ASIC, APRA, the Australian Federal Police, or a legal practitioner for advice about the protections, or as that Part otherwise permits — and we can still investigate the substance of a qualifying report while taking reasonable steps to reduce the risk that you are identified.

If your concern relates to a member of company leadership, say so in your report. We will arrange for someone not implicated in the concern to review and respond to it, to the extent our current size allows. You can also report directly to an external regulator such as ASIC without reporting to us first; section 7 explains how those statutory protections work.

We will not tolerate detrimental treatment of someone because they made a report under this policy in good faith, whether or not the concern is later substantiated. Good faith means you genuinely and honestly believe the concern you are reporting is real — it does not mean the concern has to turn out to be correct. This protection does not extend to a report you know to be false when you make it.

Detrimental treatment includes dismissal, demotion, discrimination, harassment, intimidation, or any other unfavourable treatment connected to a report, whether it affects your employment or engagement with us or, for a customer or member of the public, our business relationship with you. If you believe you have experienced detrimental treatment because you made a report, tell us at ethics@aicial.com so we can address it.

We will:

• acknowledge your report, where you have given us a way to reach you;
• assess it to understand what it concerns and how serious it is; and
• take action proportionate to what we find, which may include an internal investigation, a change to a policy or process, or referral to an appropriate external authority where the law requires it or we judge it necessary — always subject to the identity protections in section 3, including the stricter confidentiality rule that applies where your disclosure qualifies for protection under Part 9.4AAA of the Corporations Act 2001 (Cth).

We handle a report within a reasonable period. Where you have identified yourself, and it is practicable to do so without compromising an investigation or another person’s rights, we tell you the outcome or the reason we cannot share it.

Aperim Pty Ltd is an early-stage company. ethics@aicial.com is currently reviewed by company leadership, and accountability for this policy sits with them today. We do not currently operate an independent whistleblower hotline or employ a dedicated whistleblower protection officer. As the company grows, we intend to formalise a more independent reporting channel, proportionate to that growth, and we will update this policy when we do.

This policy binds every aicial employee and contractor. Anyone who handles a report under this policy must handle it, and the identity of the person who made it, in accordance with this policy — and, where a report is or may be a qualifying disclosure under Part 9.4AAA of the Corporations Act 2001 (Cth), must seek legal advice before sharing an identified whistleblower’s identity with anyone beyond what that Part permits.

This policy operates alongside, and does not replace, the statutory whistleblower protections in Part 9.4AAA of the Corporations Act 2001 (Cth). Those protections apply on their own terms — including their own tests for who qualifies as an eligible whistleblower, what counts as a disclosure that qualifies for protection, and who a disclosure must be made to — to a person who meets them, regardless of anything in this policy.

Those statutory tests differ from this policy’s in kind, not just detail. This policy asks whether you made your report in good faith — a genuine, honest belief, regardless of whether it turns out to be correct. The Corporations Act instead asks whether you had reasonable grounds to suspect the conduct you disclosed; your motive for disclosing it does not affect whether the statutory protections apply. Nothing in this policy requires you to report to us before you disclose to an eligible recipient under that Part — including ASIC, APRA, the Australian Federal Police, or a lawyer for advice about the protections — and a disclosure made that way is assessed under the Act, not under this policy.

This policy is deliberately broader than that statutory scheme in who we will hear from and what we treat as in scope — it does not mean this policy gives you the same legal remedies as Part 9.4AAA where that Part applies. We want to hear a genuine concern from anyone connected to aicial, including a customer or a member of the public who may fall outside it, not only from someone who meets its specific legal tests. Nothing in this policy limits, or attempts to restate, a statutory whistleblower protection or any other legal right you may have; where the statutory scheme applies to your disclosure, it continues to apply according to its own terms.

We may update this policy to reflect changes to our practices, our governance or our legal obligations. The version, effective date and last-reviewed date shown at the top identify the current policy. We publish the updated policy on our website and, where a change is material, provide additional notice through the service or by email before it takes effect.

To make a report, or to ask a question about this policy, contact:

Aperim Pty Ltd, which operates the aicial brand
ABN 46150699737
ACN 150699737
New South Wales, Australia
Email: ethics@aicial.com