Strengthening Whistleblower Protection in Australia: ASIC’s Findings in ASIC Report 827
ASIC has reinforced the essential role of whistleblowers in maintaining corporate integrity. In its latest announcement, ASIC Commissioner Alan Kirkland stated:
“Whistleblowers play a crucial role in identifying and exposing misconduct that can harm customers, shareholders, companies and the broader community. Without effective policies and programs to encourage whistleblowers to come forward, misconduct may otherwise go unreported and undetected.”
He further noted that ASIC’s questionnaire found significant variation in the maturity of whistleblower practices.
These findings underscore a clear message: Australian organisations must lift their standards and ensure whistleblower frameworks are robust, accessible, and capable of supporting individuals who come forward.
As Stopline approaches its 25th anniversary in 2026, this call for improved practices is both timely and aligned with our core mission. Established in 2001 as Australia’s first dedicated whistleblower hotline, Stopline has helped organisations nationwide embed best-practice processes for receiving, managing, and resolving disclosures safely and independently.
What ASIC’s Findings Reveal About Current Whistleblower Practices
ASIC’s media release, 25-294MR ASIC calls on Australian companies to adopt better practices to protect whistleblowers, reflects the outcomes of its “first-of-its-kind” whistleblower questionnaire. As ASIC reported:
“significant differences in the whistleblower policies and practices adopted across corporate Australia, and highlighted opportunities for companies to better support and protect those who speak up.”
While some organisations have developed comprehensive, accessible systems, many others have not. Among 134 companies surveyed, ASIC found:
• Over one-third had no dedicated whistleblower reporting webpage.
• One-quarter did not provide regular staff training on whistleblower processes.
• More than half had not sought employee feedback on their program in the prior year.
• Several organisations lacked mechanisms for anonymous two-way communication, a core requirement for trust and safety.
These systemic gaps—particularly around accessibility, governance oversight, and training—pose risks not only to disclosers but to organisations themselves. Poorly handled disclosures can lead to delayed detection of misconduct, breaches of legal obligations, cultural deterioration, and reputational harm.
ASIC Report 827 Reinforces the Regulatory Expectations
ASIC’s recently released Report 827 – Insights from the ASIC Whistleblower Questionnaire: July 2024 to June 2025 further clarifies the importance of strong internal policies. Report 827 states:
“Effective whistleblower policies and programs encourage individuals to come forward with their concerns. These policies and practices are essential for uncovering misconduct within the corporate sector that may otherwise go undetected. Recent high-profile misconduct allegations by whistleblowers have highlighted the need for effective policies and procedures within organisations.”
The report also reiterates legislative obligations:
“Public companies, large proprietary companies, and corporate trustees of registrable superannuation entities must have a whistleblower policy.”
This reinforces not only the legal requirement but also ASIC’s broader expectation that organisations ensure their frameworks are fit for purpose.
Why Whistleblower Programs Need to Be More Than Compliance Documents
ASIC’s findings show that too many organisations treat whistleblower systems as static policy documents rather than operational governance tools. Commissioner Kirkland stressed that whistleblower systems are foundational to organisational integrity and must be embedded in both governance structures and everyday practice.
He recommended that companies:
“benchmark themselves against the findings of the report and consider how they can improve their own whistleblower policies and practices.”
Benchmarking, when done correctly, requires organisations to assess:
• how accessible their reporting channels are;
• whether confidentiality and anonymity can be genuinely maintained;
• how well investigations are documented, tracked, and governed;
• whether staff—including managers and disclosure officers—are adequately trained;
• the quality of reporting provided to boards and audit committees;
• the maturity of organisational culture around “speaking up”.
These expectations align directly with Stopline’s longstanding service model.
Stopline’s 25-Year Role in Supporting Governance Excellence
For nearly 25 years, Stopline has partnered with organisations across Australia to build safe, trusted, independent whistleblower systems that uncover issues early, reduce organisational risk, and support ethical workplaces.
Our services include:
• Dedicated whistleblower hotline support
• Secure online reporting channels
• Anonymous two-way communication capabilities
• Independent disclosure assessment and triage
• Board-level reporting and analytics
• Training for staff, managers, and disclosure officers
A critical component of this support is our Australian-built Make a Report (MAR) case management platform. MAR’s structured workflows, access controls, time-stamped audit trails, and comprehensive documentation capabilities directly address the governance gaps identified by ASIC. Organisations using MAR can demonstrate:
• consistent handling of disclosures;
• audit-ready investigation records;
• measurable system performance (e.g., timeliness, resolution metrics);
• risk and trend data for boards and audit committees;
• improved compliance with legislative and regulatory expectations.
Independent systems like Stopline and MAR also strengthen employee trust. Individuals are more likely to report concerns when they know the process is external, impartial, and confidential—and that they can remain anonymous without compromising the integrity of the investigation.
Boards and executives are now expected to demonstrate stronger oversight of whistleblower programs.
ASIC’s findings make it clear that organisations must ensure their reporting channels, processes, and governance practices meet evolving regulatory expectations and effectively protect individuals who choose to speak up.
With 25 years of national experience, Stopline can help your organisation benchmark its current whistleblower program against ASIC’s findings and implement a best-practice framework that protects individuals, strengthens organisational culture, and reduces governance risk.
Request a consultation with Stopline to ensure your whistleblower processes align with regulatory requirements and emerging industry standards.
Andrew McLeish
CEO & Managing Director, Stopline Pty Ltd
(m) 0487 333 099
(e) andrewmcleish@stopline.com.au
References
Australian Securities and Investments Commission (2025). ASIC calls on Australian companies to adopt better practices to protect whistleblowers.
Australian Securities and Investments Commission (December 2025). Report 827: Insights from the ASIC Whistleblower Questionnaire: July 2024 to June 2025.
ASIC Report 827 - Insights from…