Not-for-profit Law
Legal help for community organisations

Whistleblower policy template now available!

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Who must have a whistleblower policy?

From 1 January 2020, your organisation must have a whistleblower policy if it is:

  • a trading or financial corporation (including trading or financial incorporated associations registered with ASIC as Registered Australian Bodies); or
  • a company limited by guarantee with an annual consolidated revenue over $1 million.

If you are not sure whether your organisation is a trading or financial corporation, refer to ASIC’s guide on this.

While not-for-profit companies limited by guarantee (that aren’t trading or financial corporations) 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. And 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.

Justice Connect’s Privacy Policy is available at https://www.justiceconnect.org.au/privacy. The policy contains important information about how you can access and request correction of information we hold about you, how you may complain about a breach of the Australian Privacy Principles and how we will deal with any privacy complaint.

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