Review the whistleblower policy against the Act and ASIC’s guidance
Key facts
- Human involvement
- YellowClose supervision
- How AI is used
- Compare the current policy clause by clause with the Part 9.4AAA content requirements and the RG 270 good-practice points, mark each requirement as covered, partly covered or missing with the policy clause cited, and draft replacement wording for the gaps from the team’s approved precedent.
- What the lawyer must review
- The lawyer checks every gap and every drafted clause against the Act and RG 270, confirms the named eligible recipients and contact channels are real and current, decides whether the entity is required to have a policy or is adopting one voluntarily, and settles the wording before board approval.
- Written for / version
- US
Open a jurisdiction version of this task to see which instruments apply: US
Who does what
| Role | What they do |
|---|---|
| Assistance | Compare the current policy clause by clause with the Part 9.4AAA content requirements and the RG 270 good-practice points, mark each requirement as covered, partly covered or missing with the policy clause cited, and draft replacement wording for the gaps from the team’s approved precedent. |
| Lawyer | Set the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output. |
Checklist
- Confirm the entity type: public company, large proprietary company or corporate trustee of an APRA-regulated superannuation entity.
- Check each covered requirement is covered by text in the policy, not by a cross-reference to a document employees cannot see.
- Confirm every named recipient, hotline and email address is live and staffed.
- Check the policy says how it is made available to officers and employees.
Sources
- ASIC Regulatory Guide 270 Whistleblower policies · 2026-10-18
- ASIC — Whistleblowing · 2026-10-18
- Corporations Act 2001 (Cth) — Federal Register of Legislation · 2026-10-18
These are suggested working checks. Confirm the required checking with the responsible lawyer before work starts; the checking approach does not establish permission to use AI.