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Sunday, December 7, 2025

ASIC Report 827 on whistleblowing practices of 134 surveyed companies: how does your company stack up? - Herbert Smith Freehills Kramer

On 4 December 2025, ASIC published Report 827, Insights from the ASIC Whistleblower Questionnaire: July 2024 to June 2025(Report). The Report sets out the findings of a questionnaire conducted by ASIC into the whistleblowing policies and procedures of 134 Australian companies during the period July 2024 to June 2025 based on self-reported responses of the surveyed companies (Questionnaire).

The Report aims to benchmark whistleblower practices across corporate Australia, including the level of compliance with statutory requirements, the degree of uptake of practices recommended in ASIC’s previous whistleblowing guidance, and the extent to which such practices are scalable relative to companies’ respective sizes and sectors.

The Report serves as a good prompt for companies to consider the effectiveness of their whistleblowing practices:

  1. Ensure that reporting channels are visible, accessible and foster trust. Companies surveyed that had dedicated whistleblower webpages and hotlines saw higher rates of disclosure than that did not, which ASIC attributed to the anonymity and ease of reporting that such channels offer.
  2. Ensure there is high engagement with employees on whistleblowing practices. Companies who regularly shared information about their whistleblower programs and provided recurring training achieved higher disclosure rates than those that did so as a one-off. Consider sharing information about your company’s whistleblower program through posters and periodic...


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