---
title: "Whistleblower policy (Corporations Act Part 9.4AAA and tax whistleblowers), with rules for AI and case-management tools"
url: "https://ailawframework.com/precedents/in-house-general-counsel/whistleblower-policy"
type: "precedent"
site: "AI Law Framework"
id: "a40-whistleblower-policy"
area_id: "A40"
kind: "policy"
ai_level: "yellow"
version: 1
law_stated_as_at: "2026-10-17"
---

# Whistleblower policy (Corporations Act Part 9.4AAA and tax whistleblowers), with rules for AI and case-management tools

> A whistleblower policy that covers every matter s 1317AI(5) of the Corporations Act requires, explains tax whistleblower protections, and adds strict rules so disclosures and identifying information never go into…

Canonical page: https://ailawframework.com/precedents/in-house-general-counsel/whistleblower-policy  
Law stated as at: 2026-10-17

Site index for agents: https://ailawframework.com/llms.txt

A whistleblower policy that covers every matter s 1317AI(5) of the Corporations Act requires, explains tax whistleblower protections, and adds strict rules so disclosures and identifying information never go into unapproved AI, transcription or translation tools.

## Key facts

- Kind: Policy. A policy or procedure for a firm or client.
- Practice area: [In-House / General Counsel](https://ailawframework.com/precedents/in-house-general-counsel.md)
- Jurisdictions: Australia
- AI level: Yellow. AI can help in set ways. A lawyer checks specific points before use.
- Law stated as at: 2026-10-17
- Status: Maintained. Checked on 2026-10-17 against the 7 authorities it cites, for Australia.

## When to use it

Use for public companies, large proprietary companies and trustees of registrable superannuation entities, which must have a policy (ASIC has relieved not-for-profit public companies limited by guarantee with annual revenue under $1 million), and for other organisations that want one. Check sector rules (for example, banking and superannuation) and ASIC's current Regulatory Guide 270 before finalising.

## How AI may be used

AI may help draft and maintain the policy and its training materials. Disclosures, and anything that could identify a discloser, must stay out of AI tools unless Legal has approved a tool for that purpose with strict access controls; AI never decides whether a disclosure qualifies.

**AI may:**

- Draft and update the policy and plain-English training materials from this precedent and the legislation, for legal review.
- Check the policy against each paragraph of s 1317AI(5) and list gaps.
- Prepare de-identified statistical reports for the board from data that has already been de-identified by an authorised officer.

**AI must not:**

- Must not receive a disclosure, the discloser's identity or information likely to identify them, except in a tool approved under clause 10.
- Must not decide whether a disclosure qualifies for protection, whether to investigate, or what the outcome is.
- Must not transcribe or translate whistleblower interviews in a general-purpose AI tool.

**The lawyer checks:**

- Every matter in s 1317AI(5) is covered and the policy is available to officers and employees.
- Eligible recipients and the external channel are named and current.
- The case-management and any AI tools meet clause 10 and access is logged.

## Authorities

- [Corporations Act 2001 (Cth) Pt 9.4AAA (protection for whistleblowers)](https://www.legislation.gov.au/C2004A00818/latest/text)
- [Corporations Act 2001 (Cth) ss 1317AA, 1317AAA and 1317AAC (qualifying disclosures; eligible whistleblowers; eligible recipients)](https://www.legislation.gov.au/C2004A00818/latest/text)
- [Corporations Act 2001 (Cth) ss 1317AAD and 1317AADA (public interest and emergency disclosures; personal work-related grievances)](https://www.legislation.gov.au/C2004A00818/latest/text)
- [Corporations Act 2001 (Cth) ss 1317AAE, 1317AB, 1317AC, 1317AD and 1317AE (identity protection; immunities; victimisation; compensation and remedies)](https://www.legislation.gov.au/C2004A00818/latest/text)
- [Corporations Act 2001 (Cth) s 1317AI (whistleblower policies)](https://www.legislation.gov.au/C2004A00818/latest/text)
- [Taxation Administration Act 1953 (Cth) Pt IVD (tax whistleblowers)](https://www.legislation.gov.au/C1953A00001/latest/text)
- [ASIC Regulatory Guide 270 Whistleblower policies (link only)](https://www.asic.gov.au/regulatory-resources/find-a-document/regulatory-guides/rg-270-whistleblower-policies)

## Official form

[Official form](https://www.asic.gov.au/regulatory-resources/find-a-document/regulatory-guides/rg-270-whistleblower-policies)

## Full text and drafting notes

The full text and the drafting notes are not part of this public page. Signed-in firm accounts can read them at https://ailawframework.com/precedents/in-house-general-counsel/whistleblower-policy and through the signed-in MCP connector https://ailawframework.com/mcp/firm.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*