Whistleblower Policy Template (APRA & AFSL Regulated Businesses)

This Whistleblower Policy template is designed for Australian organisations that need a comprehensive, compliance‑focused whistleblowing framework, rather than a basic startup‑level document. It is suited to:

• APRA‑regulated entities (including where CPS 520 Fit & Proper is relevant);
• AFSL/ACL holders and other ASIC‑regulated businesses with formal governance structures;
• Growing, mid‑sized or more mature corporates with an established compliance or risk function;
• Corporate groups with multiple entities that require consistent whistleblowing standards.

What this template covers:

• Purpose, goals and organisational commitment to speaking up and ethical behaviour;
• Who is covered by the policy (eligible whistleblowers, including employees, officers, contractors and related parties);
• What conduct can be reported and which disclosures fall outside whistleblower provisions;
• Detailed reporting channels (internal contacts, alternate contacts, external regulators, auditors and legal practitioners);
• Options for anonymous reporting and how anonymity is protected in practice;
• Investigation process: receipt, assessment, investigation, reporting to senior management and the Board;
• Protections against detriment and retaliation, including escalation pathways where retaliation is suspected or has occurred;
• Ongoing training, communication and onboarding requirements;
• Governance, Board reporting, policy review and document control;
• Legislative and regulatory sources, including Corporations Act Part 9.4AAA, ASIC RG 270, ASIC information sheets and (where relevant) APRA prudential standards.

You receive an editable Word document with placeholders for your organisation name, roles, reporting channels and governance details, so it can be adapted across different regulated businesses. This template is best suited to growing, mid‑sized or more mature organisations – particularly APRA/ASIC‑regulated entities – that need a robust internal reporting and investigation framework with formal reporting and governance processes.