Effective Date: 1 December 2025
Version: 4.0
Issuing Entity
Superspeed.ai Pty Ltd (ACN 660 530 090), trading as Cushi.app
Parent Governance Entity
Strategic Global Holdings Pty Ltd (ACN 693 256 503), Queensland, Australia
Governing Law
Australia
Review Cycle
Reviewed at least annually or earlier where required by law or material operational change.
1. PURPOSE
This Policy establishes a framework for reporting suspected misconduct and outlines protections available under applicable Australian law.
This Policy is intended to comply with Part 9.4AAA of the Corporations Act 2001 (Cth).
Nothing in this Policy limits or replaces rights and protections available under applicable legislation.
2. WHO CAN MAKE A PROTECTED DISCLOSURE
Eligible whistleblowers may include individuals defined under the Corporations Act 2001 (Cth), including:
- Current and former employees
- Officers and directors
- Contractors and suppliers
- Associates of the company
- Relatives or dependants of eligible individuals
Eligibility is determined in accordance with applicable law.
3. DISCLOSABLE MATTERS
A protected disclosure may relate to misconduct or an improper state of affairs or circumstances in relation to the company.
Examples may include:
- Breaches of law
- Fraud, corruption, or bribery
- Serious misconduct
- Systemic governance failures
- Conduct posing a risk to the public or financial system
- Significant data misuse or security concerns
Personal work related grievances are generally not protected disclosures unless they involve victimisation or systemic misconduct as defined by law.
4. HOW TO MAKE A DISCLOSURE
Disclosures may be made to an eligible recipient under the Corporations Act, including:
- An officer or director of the company
- A senior manager
- An auditor or authorised representative
- A qualified legal practitioner for the purpose of obtaining legal advice
Internal reporting channels include:
Nothing in this Policy prevents a whistleblower from making a disclosure directly to an eligible regulator in accordance with law, including ASIC or APRA.
5. CONFIDENTIALITY
The identity of a whistleblower will not be disclosed except:
- With the whistleblower’s consent; or
- As permitted or required by law
Information that is likely to identify a whistleblower will be handled in accordance with statutory confidentiality requirements.
Access to disclosure information is restricted to authorised personnel.
6. PROTECTION FROM DETRIMENT
It is unlawful to cause detriment to a whistleblower because they have made, or may make, a protected disclosure.
Detriment may include dismissal, injury, harassment, discrimination, threats, or other adverse treatment.
Cushi.app prohibits retaliation and will take reasonable steps to reduce the risk of victimisation.
7. INVESTIGATION PROCESS
Upon receiving a disclosure:
- The matter will be assessed to determine whether it qualifies as a protected disclosure
- An appropriate and confidential review process may be initiated
- Conflicts of interest will be managed where identified
The timeframe and scope of investigation will depend on the nature and complexity of the matter.
8. FAIR TREATMENT
Cushi.app will take reasonable steps to ensure fair treatment of individuals mentioned in disclosures.
Investigations will be conducted objectively and in accordance with procedural fairness principles.
9. ANONYMOUS DISCLOSURES
Whistleblowers may choose to remain anonymous when making a disclosure.
Anonymous disclosures may limit the company’s ability to investigate or provide feedback.
10. FALSE OR MISLEADING DISCLOSURES
Disclosures made in good faith are protected even if they are not substantiated.
Deliberately false or malicious disclosures may be subject to appropriate action.
11. RECORD KEEPING AND PRIVACY
Disclosure records are handled securely and in accordance with privacy obligations.
Identifying information is restricted to those authorised to access it.
Records are retained in accordance with legal and operational requirements.
12. REVIEW
This Policy is reviewed periodically and updated where required by law or operational change.
CONTACT
Superspeed.ai Pty Ltd
Brisbane, Australia
whistleblower@cushi.app
privacy@cushi.app
VERSION CONTROL AND GOVERNANCE
Version 4.0
Effective 1 December 2025
Approved by Chief Executive Officer, Superspeed.ai Pty Ltd© 2025 Superspeed.ai Pty Ltd (ACN 660 530 090), trading as Cushi.app
Part of the Strategic Global Holdings Pty Ltd group (ACN 693 256 503)