Not-for-profit Law
Legal help for community organisations

Whistleblower policy template now available!

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Who must have a whistleblower policy?

Your organisation must have a whistleblower policy if it is a company limited by guarantee with an annual consolidated revenue of $1 million or more.

While not-for-profit companies limited by guarantee with an annual consolidated revenue of less than $1 million are not required to have a whistleblower policy, they must still comply with the whistleblower protection provisions in the Corporations Act.

Note that the whistleblower protection laws under the Corporations Act also apply to corporations which meet the definition of a ‘trading or financial corporation’ under the Australian Constitution (these may include incorporated associations and other structures not incorporated under the Corporations Act, if they are a ‘trading or financial corporation’). If you are not sure whether your organisation is a trading or financial corporation, refer to ASIC’s guide on this.

For these entities, the best way to demonstrate compliance may still be to have a whistleblower policy.

How do I prepare a whistleblower policy?

A whistleblower policy must include information about:

  • protections available to whistleblowers
  • how and to who the whistleblower may make the disclosure
  • how the company will support whistleblowers and protect them from detriment
  • how the company will investigate disclosures
  • how the company will make sure employees mentioned in disclosures, or related to disclosures, will be fairly treated, and
  • how the policy will be made available to officers and employees

Fill out the form below to download a whistleblower policy template and prepare a whistleblower policy for your organisation. ASIC has also published a guide (Regulatory Guide 270) to help organisations prepare a whistleblower policy that complies with the Corporations Act. 

Note: The template policy doesn’t consider your organisation’s particular legal structure, needs or operations. The information in the template policy is not legal advice. You might need legal advice on your particular situation.

Whistleblower policy template

This whistleblower policy is based on ASIC Regulatory Guide 270.

Note

Not-for-profit Law, a service of Justice Connect, will not disclose the contents of this form, but may use de-identified information when reporting on the types of organisations accessing this template.

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