Challenger Capital Notes 2 (CGFPB)


We believe in doing the right thing, and integrity, honesty and compliance are at the heart of how we operate at Challenger. We actively encourage our employees (including contractors), former employees, suppliers, service providers and relatives to speak up and report any concerns of wrongdoing. We do this by providing a trusted avenue to make a disclosure and providing support throughout the process to help those who raise concerns. 

Individuals are often concerned about being identified or the potential repercussions of reporting misconduct. Our comprehensive Whistleblower Policy provides a safe and supportive environment to raise concerns as protections are available to individuals raising concerns. 

When submitting a ‘protected disclosure’ (as defined in the Whistleblower Policy), individuals will have the benefit of anonymity by having their identity protected. Whistleblowers are protected under the law from ‘detrimental conduct’, which includes retaliations such as dismissal, discrimination or other disadvantages to the individual. Our Whistleblower Policy provides more information about how these protections work.

Our Whistleblower Policy outlines the concerns that we would like to be made aware of. This includes conduct that is: 

  • dishonest; 
  • fraudulent; 
  • corrupt; 
  • illegal; 
  • in breach of legal obligation (e.g. legislation); 
  • in serious breach of internal policy; 
  • unethical, improper or unsafe;
  • bullying and harassment; or
  • any other conduct which may cause financial or non-financial loss to Challenger or be otherwise detrimental to the interests of Challenger and its customers, including environmentally unsound practices of a material nature.

How individuals can raise a concern 

There are a number of ways our employees and stakeholders can report any concerns about misconduct or wrongdoing, and we encourage doing this in the way they feel most comfortable. These include: 

  • Our employees raising their concerns with their leader or a trusted leader;
  • Directly reporting concerns to a member of the Challenger Leadership Team such as the Chief Risk Officer or Chief Executive, People, Corporate Affairs and Sustainability;
  • Directly reporting to a director or a company secretary in person, or by email or postal service;
  • Directly reporting to the Challenger Life Company Appointed Actuary;
  • Directly reporting to an Audit Partner of KPMG or EY;
  • Reporting to our independent whistleblower service via web, phone or mail. Anonymous reporting is available through all the below channels:
    • A dedicated hotline: 1300 790 228 (Australia) or +61 3 9895 0012 (International)
    • Online at using CGF as the organisation ID
    • Mail to Locked Mail Bag 7777, Malvern VIC 3144 Australia

Whistleblower process

All concerns raised will be taken seriously and investigated. Action will be taken as appropriate and will vary from case to case.

Within five working days, the Whistleblower will receive an acknowledgement - either directly (if contact details have been provided) or via our whistleblower portal if the Whistleblower has chosen to remain anonymous.

We may ask for further information and, in some cases, we may only be able to provide limited details of our investigation and response, due to privacy or legal restrictions. You will be able to provide feedback as to whether the response has addressed your concern.

View the Challenger Whistleblower Policy for more information.