Last Updated 26 August 2025
This Whistleblowing Policy (Policy) is designed to encourage, protect and support responsible reporting of misconduct, actions which are illegal, conduct which is indicative of systemic issues, dishonest or unethical behaviour or practices, and financial misconduct as it relates to Envato and its affiliates (collectively Misconduct, set out in more detail under the Policy Guidelines section), in accordance with this Policy and applicable laws.
This policy is underpinned by our values of “Build our future”, “Community spirit”, “Embrace diversity”, “Make Envato proud” and “Make it happen”, which guide our behaviour and apply to every aspect of our business.
Our Board of Directors is dedicated to maintaining the highest ethical standards, good corporate governance and compliance practices.
This Policy applies to:
This Policy applies regardless of whether you are working for Envato in Australia, New Zealand, Mexico, United Kingdom or any other country (excluding the United States of America).
This policy does not apply to team members employed in the United States. You will be covered by Shutterstock’s Whistleblower Policy.
As an Envato team member and supplier, you play a role in the prevention, detection and reporting of Misconduct. Your behaviour and conduct can directly impact Envato’s brand and reputation, and in living the Envato Values, we rely on all Envato team members and suppliers to act ethically and with integrity.
You must:
It is Envato’s policy to comply with all applicable laws to protect whistleblowers against unlawful retaliation as a result of their lawful reporting on reasonable grounds, or participation in investigations involving alleged Misconduct.
Any victimisation, retaliation or detriment caused or threatened to be caused in reprisal for a report will be treated as misconduct and may result in disciplinary action, which may include termination of employment.
Matters which do not relate to the Misconduct described in this Policy are not subject to reporting under this Policy. Please refer to Envato’s Grievance Policy for personal work-related grievance reporting.
Envato discourages the use of this Policy for malicious or false reporting. Any individual found to have knowingly made a false report may be subject to disciplinary action.
Envato must take steps to protect the confidentiality of a report and identity of the whistleblower making reports on reasonable grounds, as required by applicable laws. Envato may disclose your identity where:
If you are the recipient of a report from a whistleblower, you must not reveal the identity, or information that is likely to lead to identification, of the whistleblower without the written consent of the whistleblower or express permission from the Envato General Counsel to make the disclosure. Such actions may be illegal in certain jurisdictions, such as Australia.
A report should include as much of the following information as possible:
If you wish to be identified, you may contact:
If you wish to make an anonymous report, you can contact our third party whistleblowing service Your Call in the following ways:
Your Call uses an online message board which you will have access to after making the report. The message board allows you to:
As Envato is a part of the Shutterstock Inc. group, notifications and reporting will be provided to both Shutterstock & Envato. A copy of your report from Your Call will be received by each of:
If your report relates to any one of these people, Your Call will exclude that person from all communications when they provide information about your report to Your Call.
While it is Envato’s desire to address matters internally, nothing in this Policy prohibits those included in the scope of this Policy from reporting any illegal activity to the appropriate regulatory authority. For example, you may report matters directly to the Australian Securities and Investments Commission (ASIC), the New Zealand Financial Markets Authority (FMA), or Mexico’s National Banking and Securities Commission (CNBV), depending on the nature of the issue. You may also seek independent legal advice.
So as to ensure whistleblowers are supported both during, and following the making of a report, Envato encourages whistleblowers to make use of Envato’s employment assistance program or EAP provider Career Money Life or Envato Cares.
All reports will be reviewed, and where appropriate will be investigated at the earliest opportunity. Envato will endeavour to manage any findings promptly. The way a disclosure is managed depends on what it involves and will be dealt with on a case by case basis.
Generally, if the whistleblower can be contacted, Envato will confirm receipt of their report within two (2) Business Days. Where an investigation of a report is deemed appropriate, Envato will endeavour to commence the investigation as soon as reasonably practicable from the date Envato receives the report. However, there may be reasons why an investigation may take longer, or may not be practicable.
Envato will expect those involved in the investigation to keep the subject matter of the investigation confidential. However, certain disclosures may need to be made for the reasonable conduct of the investigation and the proper resolution of the matter being investigated. Other protections set out under this Policy will apply to the investigation. The investigation will be undertaken by an appropriate person selected by Envato and/or outside Envato, depending on the nature of the investigation.
In order to enable the conduct of fair and unbiased investigations and actions, it may be necessary for Envato to:
In the conduct of an investigation, Envato may proceed as follows:
The findings of any investigation into a disclosure (together with any remediation action plan) will be subject to the confidentiality obligations set out in this Policy. The method for documenting and reporting the findings will depend on the nature of the disclosure. In most cases, a final investigation report will be provided to each of Envato’s Chief People Officer, General Counsel, Chief Executive Officer and each of Shutterstock’s Deputy General Counsel, Vice President of Internal Audit and the Board of Directors’ Audit Committee Chair. In the case of a report concerning tax or financial affairs, the final investigation report will also be provided to Envato’s Chief Financial Officer. Where the whistleblower has not consented to their identity being shared, any final investigation report will be redacted to protect the whistleblower’s identity or information that may identify the whistleblower.
Envato also aims to ensure the fair treatment of team members and other persons engaged by Envato who are referred to in reports, which includes the opportunity to be ‘heard’ on, and respond to the allegations against them before any adverse findings are made against them, and the opportunity to have their responses considered by Envato and, in appropriate circumstances, investigated.
Envato will, where appropriate, provide the whistleblower with updates at various stages of any investigation into a report. Any updates supplied to a whistleblower may need to be limited in order to also preserve the confidentiality of an investigation and the privacy of those potentially affiliated, named, implicated or associated with the matters disclosed. The frequency and detail of any updates supplied (where appropriate), and the initiation or resolution of any potential subsequent investigation, may vary according to the matters reported and the context of the misconduct disclosed.
Envato will, where appropriate, advise the whistleblower of the conclusion of any investigation and may provide the whistleblower with details of the outcomes of that investigation. Where claims cannot be substantiated, Envato reserves the right to deem a disclosure closed and notify the whistleblower accordingly (where the whistleblower’s identity is known).
The penalties for failing to comply with whistleblower laws are significant and can include:
The Envato Board of Directors, and at times the Shutterstock Board and/or Audit Committee, will generally be provided with confidential reports on the number and type of whistleblowing incidents quarterly to enable it to address any issues at a regional or group level. The Board will also usually be provided with additional information about any material incidents raised.
This Policy will be available to officers and team members of Envato on the intranet. A copy of this Policy will also be available on Envato’s website to ensure it is accessible for all eligible whistleblowers.
This Policy will be periodically reviewed to ensure that it is operating effectively and to assess if updates are needed.