Whistleblower Programs Under the Spotlight: What ASIC’s Corporate Plan 2025-26 Means for your Organization

Implications at a glance

1. Regulatory risk rises
   ASIC’s announcement means whistleblower programs will not be a “nice to have,” but a focus of regulatory review. If a company’s program is found deficient (e.g., inadequate protections, poor triage, lack of board oversight) then enforcement and reputational consequences may follow.     
2. Benchmarking and transparency
   The benchmarking review means programs will be compared. Organizations with weaker systems may be exposed, while those with mature frameworks may experience peer pressure or expectations to disclose program metrics internally or externally.     
3. Cultural and operational demands
   Effective whistleblower programs go beyond ticking the box. ASIC’s Report 758 shows the most effective programs combine strong governance, trained people, accessible channels, data-driven insights, and continuous review.

Six key recommendations to get ready

Here are the six recommendations each tied to the pillars in Report 758.

1.     Build a strong foundational infrastructure

• Ensure the whistleblower policy is documented and compliant with the Corporations Act and relevant regulatory guidance
• Define clear roles and responsibilities who receives disclosures, who investigates, conflict-reset, backup delegates
• Develop procedures and workflows triage, investigation, data management, confidentiality and ensure IT/security controls protect whistleblower identity and data
• Allocate adequate resources (staff, technology, budget) to support the program

2.     Foster a speak-up culture and protect whistleblowers

• Communicate the program across channels: intranet, town halls, training, and embed “speak-up” messaging so that employees, contractors and external stakeholders see it as a trusted pillar of your culture
• Provide accessible reporting channels (hotline, web portal, internal email) and ensure these channels are well-publicized and easy to use
• Ensure robust processes to support whistleblowers: confidentiality safeguards, non-retaliation measures, risk assessments for potential detriment

3.     Provide training and resources

• Conduct regular training for recipients of disclosures (internal “eligible recipients”), investigators, legal/compliance teams and senior management to ensure they understand their obligations
• Provide quick-reference guides, process maps, templates and refresher modules
• Tailor training and resources across senior management, board, employees and external persons as needed

4.     Monitor, review and continuously improve

• Define metrics and key performance indicators (KPIs) for the whistleblower program (usage rates, response times, closure rates, root-cause remediation)
• Schedule periodic reviews of the program (policy, procedures, channels) and consider external audits or maturity assessments
• Use feedback from whistleblowers or internal surveys to detect trust/resistance points in the program

5.     Use the information to drive improvement

• Analyze disclosures: what trends are emerging? Are there systemic or organizational issues underlying repeated disclosures?
• Map disclosures to operational risk and compliance functions, feed insights into risk registers, audit scope, training enhancements
• Report upward: ensure senior management/board receive insight-reports that allow them to act strategically

6.     Embed senior executive and board oversight

• Ensure the board or a suitable board committee monitors the program: set reporting frequency, agenda items, dashboards, thematic trends
• Build in escalation thresholds (e.g., if disclosure raises potential regulatory obligation or systemic risk, immediate board escalation)
• Ensure there is documented evidence of oversight and decision-making: minutes, dashboards, follow-ups

How NAVEX can support you

At NAVEX, we specialize in helping organizations build and scale whistleblower, incident-reporting and ethics programs that align with regulatory expectations and best practice culture. Key offerings include:

• Anonymous reporting channels (hotline, web portal, multi-language, multi-jurisdiction)
• Case-management workflows that ensure triage, investigation, remediation tracking, audit trails
• Dashboards and analytics to provide insight into speaking-up trends, root causes and remediation
• Program-maturity assessments, benchmarking and continuous improvement support

With ASIC putting your whistleblower program under the spotlight, this is the ideal time to review your framework, close gaps and demonstrate readiness.