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ACC Australia provides submission to ASIC
Consultation Paper (CP) 321 Whistleblower Policies

Following the direction and input from the ACC Australia Advocacy Committee, ACC Australia provided a written submission to ASIC in response to ASIC and their proposed guidance for entities that must have a whistleblower policy. ACC Australia (ACC) acknowledges the importance of having internal policies and procedures in place to support and protect staff who make or may make disclosures about wrongdoing. While ACC Australia is broadly supportive of the proposed guidelines for entities that must have a whistleblower policy – public companies, large proprietary companies and proprietary companies that are trustees of registrable superannuation entities, ACC offers three points of feedback and comment on Consultation paper 321 and Draft Guidance:

  • ACC Australia is pleased that ASIC good practice guidance expresses a preference for internal reporting.
  • ACC Australia believes the ASIC good practice guidance on roles and responsibilities under a whistleblower policy overly prescriptive and further believe ASIC should revise this section to be more principles-based.
  • ACC Australia request further guidance on protections that might be afforded to in-house legal counsel (IHLC) when the IHLC themselves are put into a position where they feel it necessary to become whistleblowers.

Click here to read ACC Australia’s full submission.