The ASX Corporate Governance Council recently released a review of how listed companies are complying with the 4th edition of the Corporate Governance Principles and Recommendations.

The review, conducted by KPMG, analyses data from listed entities for the 2021 calendar year and highlights “good practice” examples for good governance and where companies are struggling to get it right.


Corporate Governance Guidelines require listed companies to have a whistleblowing policy

The 4th edition of the Corporate Governance Principles and Recommendations significantly enhances principle 3 and requires the Board to instill a culture of acting lawfully, ethically and legally.  This includes the requirement to have a whistleblowing policy:

Recommendation 3.3: Whistleblower policy
A listed entity should:

  • have and disclose a whistleblower policy; and
  • ensure that the board or a committee of the board is informed of any material incidents reporting under that policy.


What does good practice whistleblowing look like?

The review highlighted some good practice examples, including:

  • providing examples of the types of matters that may be reported under the policy
  • making it clear that employees are expected to raise concerns under the policy
  • ensuring all staff are trained in the operation of the policy
  • linking the whistleblower policy to organisational values that are aligned with acting lawfully, ethically and responsibly
  • ensuring that the Board is notified of material incidents reported under the policy
  • having in place an external independently monitored hotline service to allow for disclosures to be made anonymously.


Does your whistleblowing policy and framework pass the “good governance” test?