The information and content provided within this website is for information purposes and general guidance on matters of interest only. The information and content on this website may change from time to time and 151 Property does not guarantee the accuracy of the information on this website.
Whilst every attempt has been made to ensure the accuracy of the information and content on this website, 151 Property does not accept any responsibility as to, and does not give any warranty (express or implied) of, the reliability, accuracy, currency or completeness of any of the information on this website. 151 Property does not accept any responsibility for any loss, claim or damage which the viewer or any third party may suffer in any way (including by reason of negligence) as a result of any errors or omissions or inaccuracy in the information on this website.
The information and content on this website may include certain statements or representations concerning a property including descriptions, measurements, images, plans and layouts. Any such statements or representations must not be relied on as statements or representations of fact and persons must make their own enquiries and satisfy themselves by their own inspection, investigation or otherwise.
The information on this website may also include certain statements, estimates and projections with respect to anticipated future performance or events. Any such statements, estimates and projections are given as opinions only and reflect various assumptions by 151 Property which may or may not prove to be correct. No representations or warranties are made as to the validity of those assumptions or the accuracy of those statements, estimates or projections.
151 Property does not take responsibility for websites of other organisations, whether or not linked, or any device used to access or view 151 Property’s website.
© All rights reserved.
No part of this website may be reproduced without written permission from 151 Property, except for brief reference purposes. Republishing pages of this website in part or whole in either press or electronic format is strictly forbidden.
This email and any attachments are confidential and may contain legally privileged information or copyright material. This email is intended solely for the addressee, if you have received it by mistake you must not read, use, copy or disclose the email or any of its attachments. Please delete the email and notify the sender immediately.
151 Property is a specialist manager of real estate in Australia. It collects, holds, uses and discloses personal information to carry out its activities which include managing real estate in commercial, industrial, retail, residential and development sectors in Australia and New Zealand.
The kinds of personal information that 151 Property collects and holds may include (but may not be limited to) your:
151 Property collects personal information directly from you and in the course of our dealings with you, and in particular from correspondence, emails and business cards that you provide to us, from telephone conversations we have with you and through your use of our website. 151 Property also collects personal information from service providers, such as Link Market Services Limited, leasing agents and external legal services providers.
151 Property may also collect personal information about you from publicly available sources of information and, if you consent, from third parties (including ASIC and police checks).
If 151 Property is not able to collect personal information about you we may not be able to provide you with services and assistance to the extent that they require us to collect, use or disclose personal information, or, in the case of job applicants, assess your application for employment.
1. Use and disclosure of personal information except government related identifiers
151 Property may use or disclose your personal information for the purpose for which it was collected. 151 Property may also use or disclose your personal information for any secondary purpose that is related to a purpose for which we collected it, where an individual would reasonably expect it to be used or disclosed for that purpose.
The purposes for which 151 Property uses and discloses personal information will vary depending on your relationship with us, and may include:
151 Property will not generally disclose personal information to parties outside 151 Property, other than for a purpose directly related to our activities as a real estate investment group, unless we have your consent to do so.
In order to deliver our services to you, we occasionally need to disclose personal information to our related companies, agents, contractors or third party service providers, such as providers of administrative, telecommunications, information technology/ computer or other services. 151 Property also discloses personal information to service providers such as Link Market Services Limited.
Your personal information may be disclosed to other parties where you have expressly or impliedly consented to the use or disclosure or it is required or authorised under an Australian law or by court/ tribunal orders. For example, 151 Property discloses personal information associated with its regulatory reporting and compliance obligations, to statutory bodies such as the Australian Securities and Investments Commission.
151 Property may share personal information with related organisations in connection with the purposes described in this Policy. Some of the organisations to whom 151 Property might disclose personal information are located outside of Australia. They are generally located in the United States of America, United Kingdom, Hong Kong and Singapore. When 151 Property discloses personal information to an overseas recipient, we take reasonable steps to ensure that the personal information is handled securely and in accordance with this Policy, the Act and the APPs. We also require that these organisations use this information only for the purposes for which we collected the information (or a secondary related purpose as described above) and otherwise follow our reasonable directions with respect to this information.
2. Use and disclosure of government related identifiers
If you have provided a government related identifier to 151 Property (e.g. your Tax File Number, Australian passport number or driver licence number issued by a State or Territory authority), 151 Property will not use or disclose your government related identifier except in accordance with the Act and the APPs. For example, 151 Property may use or disclose your government related identifier if the use or disclosure of the identifier is:
As mentioned above, 151 Property may send marketing material to its customers, including, where they have opted in, via email or other digital communications. If you no longer wish to receive such promotional information from 151 Property, you should advise the 151 Property Privacy Officer using the contact details in the ‘Contact Us’ section below.
151 Property maintains strict standards and security procedures to prevent misuse, interference and loss, unauthorised access, modification or disclosure. 151 Property will take reasonable steps to ensure that the personal information it collects is accurate and up-to-date.
Personal information received by 151 Property is held electronically on secure information technology systems of 151 Property and may only be accessed by its authorised employees who require access in connection with the purposes described in this Policy. Servers are backed up daily, weekly and monthly and archives are stored in a secure location.
Personal information is also held in hard copy format. These documents are stored in lockable storage cabinets in secure premises.
We use "cookies" to enhance functionality and to keep track of visits to our website.
You can request access to personal information that 151 Property holds about you, and you can request that 151 Property corrects that personal information.
Before giving you access to your records, 151 Property will require you to prove your identity. We may ask you to verify your full name and other aspects of personal information.
151 Property will give you access to your personal information, and take reasonable steps to correct it if we consider that it is incorrect, unless there is a law that allows or requires us not to.
If 151 Property refuses to give you access to your personal information, or to correct it, 151 Property will notify you in writing and will provide reasons.
If you would like to access or correct your personal information, contact our Privacy Officer (details are below).
If you wish to make a complaint to 151 Property about how we have collected, handled, used or disclosed your personal information, you should forward a written complaint to our Privacy Officer:
Privacy Officer 151 Property Suite 602, Level 6 151 Castlereagh Street SYDNEY NSW 2000
151 Property will aim to respond in writing within 30 days of receiving a complaint.
If the complaint remains unresolved, you have the option of notifying the Office of the Australian Information Commissioner (OAIC). Contact details can be found at OAIC’s website: www.oaic.gov.au
If you have any questions or would like further information about how 151 Property handles personal information, please contact our Privacy Officer (details are above).
151 Property reserves the right to change this Policy at any time. 151 Property will notify any changes by posting an updated version of the Policy on the website.
Policy last updated: July 2017
151 Property Corporate Pty Ltd and its related companies (151 Property) are committed to the principles of ethical conduct, respect and operational excellence, and recognise the importance of all employees working towards creating a productive and harmonious workplace culture. 151 Property values teamwork, respect and integrity and wishes to encourage a culture where any officer, employee or contractor does not suffer detriment because of speaking up about potential misconduct concerns. This policy has been adopted to provide a safe and confidential environment for people to raise any such concerns without fear of reprisal.
This policy sets out:
All officers, employees and contractors of 151 Property, wherever they are based, must comply with this policy.
Officers and employees of 151 Property based in New Zealand may also be subject to additional New Zealand whistleblower requirements.
This policy is also available on our website www.151property.com.au.
You will be protected under this policy if:
This policy also protects those who are entitled to whistleblower protection under the Australian and New Zealand whistleblower laws (see section 11 of this policy).
In some cases, you may wish to obtain independent legal advice:
That communication with your legal adviser will also be protected under the Australian whistleblower laws (irrespective of the outcome of that advice).
You can make a disclosure that qualifies for protection under the Australian whistleblower laws if you are or were:
To be protected under the Australian whistleblower laws, you must make an eligible disclosure and must have reasonable grounds for that disclosure. You can still qualify for protection if your disclosure turns out to be incorrect, but you will not be protected if you make a deliberately false disclosure, which may amount to misconduct and be subject to disciplinary action.
Disclosures do not have to be about breaking the law. Eligible disclosures can be about misconduct or an improper state of affairs or circumstances that you have reasonable grounds to suspect has occurred or is occurring in relation to 151 Property. However, the disclosure cannot solely be about a personal work-related grievance to you.
Some examples of matters that are eligible disclosures are:
A personal work-related grievance is a grievance about an individual’s employment that has implications only for the individual personally (such as payroll or remuneration issues, promotion decisions, terms and conditions of engagement, or a decision to suspend or terminate your engagement or take other disciplinary action, and interpersonal conflicts), but does not have any other significant implications for 151 Property, involve a breach of workplace laws or relate to conduct about an eligible disclosure as referred to above.
Disclosures about solely personal work-related grievances are not covered by this policy and do not qualify for protection under the Australian whistleblower laws unless they also relate to any detriment or threat of detriment (as explained in section 7.3) to you.
If your disclosure is a solely personal work-related grievance, you should make it in accordance with the 151 Property Workplace Behaviour and EEO Policy which is available in the 151 Property Data Library (L:\CORPORATE STRATEGIC MANAGEMENT\Policies and Procedures).
You may make a disclosure at any time to the people identified in section 5 in person, by email, post, or delivered by hand.
If you make a disclosure from or to a 151 Property email address, your email may be accessed by certain people within its IT department in accordance with 151 Property’s policies. If you are concerned about those limited circumstances in which your email might be accessed, you may prefer to make your disclosure verbally or by mail.
All of the people listed in this section 5 can receive disclosures that qualify for protection under the Australian whistleblower laws. However, we encourage you to make your disclosure to one of our dedicated Whistleblower Protection Officers.
You can make your disclosure anonymously (and stay anonymous throughout and after any investigation) and still qualify for protection under the Australian whistleblower laws. However, 151 Property may not be able to undertake an investigation if it is not able to contact you or receive additional information from you required to fully investigate your disclosure.
If you have made your disclosure anonymously, we suggest you maintain ongoing two-way communication with 151 Property so it can ask follow-up questions or provide feedback. You can refuse to answer questions that you feel may reveal your identity at any time.
If you make a protected disclosure, it is illegal for anyone to identify you or disclose any information that is likely to lead to you being identified, unless:
Subject to the exceptions allowed under section 7.1 of this policy or otherwise by law, the identity of a discloser (or information that is likely to lead to their identity becoming known) must be kept confidential at all times during and after the investigation (including in any reporting to the Board of Directors of 151 Property Corporate Pty Limited or its related entities within the 151 Property group (Board) or to any persons affected).
All persons responsible for or involved in an investigation must take all reasonable steps to reduce the risk that a discloser will be identified.
151 Property will keep your identity and your disclosure confidential and secure by:
151 Property is committed to protecting people who make disclosures under this policy.
No-one at 151 Property (including any officers, employees or contractors) may cause or threaten any detriment to any person because they think a disclosure has been or might be made under this policy.
“Detriment” includes (but is not limited to):
If you make a protected disclosure, you will also be protected from any of the following in relation to your disclosure:
However, you may be liable for any personal misconduct revealed by your disclosure.
You may seek compensation and other remedies through the courts if:
151 Property will protect, support and monitor the welfare of anyone who makes a disclosure. This will include a risk assessment of any potential detriment, work adjustment considerations and support services such as counselling.
When you make a disclosure under this policy to one of the persons set out in section 5, your disclosure will typically be investigated as follows and by maintaining confidentiality in accordance with section 7.2:
The person who receives your disclosure will provide the information to a Whistleblower Protection Officer, as soon as practicable, ensuring your identity is protected (in accordance with section 7.1), unless you have consented otherwise.
The Whistleblower Protection Officer will determine whether your disclosure is covered by this policy and, if appropriate, appoint an investigator with no personal interest in the matter to conduct an investigation. If required, an external investigator will be appointed to ensure the investigation is handled fairly and independently or where specialist skills or expertise are necessary.
The investigator(s) will conduct the investigation in an objective and fair manner, ensuring that they give any employee who is mentioned in the disclosure an opportunity to respond to the allegations prior to any adverse findings being made against them. Those employees are also entitled to access the support services referred to in section 7.6.
If you can be contacted (including through anonymous channels), we will give you regular updates on the status of the investigation as appropriate, with the frequency and timing of such updates depending on the nature of your disclosure.
151 Property will aim to conclude the investigations as soon as reasonably practicable, and within six months of receiving your disclosure. But that time may vary depending on the nature of your disclosure.
The outcome of the investigation will be reported to the Board (protecting your identity, if applicable) and may, if the Whistleblower Protection Officer considers appropriate, be shared with you and any persons affected.
The Whistleblower Protection Officers must provide the Board or its delegated committee at least quarterly reports on all active whistleblower matters, including information on:
the number and nature of disclosures made in the last quarter (for example, by who, who to and matter type);
The Board or its delegated committee will also be immediately informed of any material incidents reported under this policy.
Our Whistleblower Protection Officers and all eligible recipients of disclosures must attend compulsory training organised by 151 Property on responding appropriately to disclosures made under this policy.
151 Property will inform its external eligible recipients about their obligations under the Australian whistleblower laws.
Our employees must attend compulsory training on our whistleblower program which will include information on how to make a disclosure, what the disclosure can be about, to whom a disclosure can make it, the protections and support available and when further information or independent legal advice might be sought.
By making a disclosure in accordance with this policy, you may be protected under the Australian whistleblower laws if the type of matter you disclose is protected by those laws.
While this policy principally deals with internal disclosures, the protections afforded by the Australian whistleblower laws (set out in section 7) also include some types of disclosure made to external parties, such as:
For more information about the Australian whistleblower laws (including how to make a disclosure directly to ASIC or the ATO), see the information available on the ASIC website (including Information Sheet 239 How ASIC handles whistleblower reports) and the ATO website.
If you are a 151 Property officer, employee or contractor based in New Zealand, you may also have protections and obligations under the New Zealand whistleblower laws.
Any breach of this policy by an officer, employee or contractor will be taken seriously by 151 Property and may be the subject of a separate investigation and/or disciplinary action.
A breach of this policy may also amount to a civil or criminal contravention under the Australian and New Zealand whistleblower laws, giving rise to significant penalties.
We encourage you to raise any concerns about non-compliance with this policy with a Whistleblower Protection Officer in the first instance. You can also lodge any concerns to ASIC or the ATO for investigation.
This policy must be reviewed by the Board or its delegated committee with the assistance of the Whistleblower Protection Officers at least every two years to ensure it is operating effectively. Any recommended changes must be approved by the Board or its delegated committee.
The Company Secretary is authorised to make administrative and non-material amendments to this policy provided that any such amendments are notified to the Board or its delegated committee at or before its next meeting.
151 Property will ensure any updates to this policy, its processes and procedures are widely disseminated to, and easily accessible by, individuals covered by this policy. Where necessary, additional training will be provided.