Whistleblower Program Compliance

Does your business comply?

Recent changes to Commonwealth legislation require that a proprietary company is a large proprietary company for a financial year if it has at least two of the following characteristics:

  • the consolidated revenue of the financial year of the company and any entities it controls is $50 million or more;

  • the value of the consolidated gross assets at the end of the financial year of the company and any entities it controls is $25 million or more; and

  • the company, and any entities it controls, has 100 or more employees at the end of the financial year.

Note: see s45A(3) of the Corporations Act and the Corporations Amendment (Proprietary Company Thresholds) Regulations 2019.

A public company, listed or not, must have a policy by 1 January 2020. This includes a public company limited by guarantee such as a charity.

A policy must contain information about the following matters:

  • the protections available to whistleblowers;

  • to whom disclosures may be made, and how they maybe made;

  • how the company will support whistleblowers and protect them detriment;

  • how the company will investigate disclosures;

  • how the company will ensure fair treatment of employees of the company who are mentioned in the disclosures that qualify for protection, or to whom such disclosure relate; and

  • how the policy is to be made available to officers and employees of the company.

The new provisions also serve to update the banking, life insurance and superannuation industries, where APRA continues its role to receive whistleblower disclosures.

If you would like some assistance about how to implement a whistleblower hotline service or ethics hotline, Stopline can help.

Stopline will help you comply with your Whistleblower Program obligations and provide…

  • straightforward and appropriate channels for the reporting of wrongdoing,

  • staff awareness of the program and their responsibility to report,

  • support for acting on anonymous reports,

  • whistleblower confidentiality to the maximum extent possible,

  • support for natural justice for the respondent.

Stopline will assist with your Management commitment to…

  • understand and promote the whistleblowing policy,

  • provide clear advice on what constitutes reportable wrongdoing,

  • provide clear advice on how to report wrongdoing,

  • investigate each whistleblowing report,

  • remedy confirmed wrongdoing,

  • provide designated officers to support each whistleblowing case.

Stopline provides easy reporting channels…

Stopline provides many customisable channels of reporting for whistleblowers or disclosers and provide anonymity and confidentiality…

  • Customised website for your business - ideal to post information about how the disclosures will be managed and any other important information for your team,

  • Dedicated email account,

  • QR Code for reporting - provides greater privacy without having the need to download an application to your phone or PC to submit a report - all accessible from your phone,

  • QR Code for accessing the customised website - all accessible from your phone,

  • National Relay Service (NRS) - for hearing impaired,

  • Telephone - response to calls is immediate and not in 24 hours - free call numbers within Australia, New Zealand and Pacific Islands, and access to more free call numbers globally,

  • Mail - post office address for mail,

  • end to end encrypted SMS and MMS service, and

  • Encrypted video conferencing.

Many of these are the minimum reporting lines required for any business to make a whistleblower service effective.

We provide quick response times for all reporting, unlike some of our competitors which state 24 to 48 hours.