Policy · Whistleblowing & Public Interest Disclosures
Whistleblower policy for a company under Corporations Act section 1317AI
A policy skeleton for a company that must set out each matter in Corporations Act s 1317AI(5), with the timing rules for a public company, a large proprietary company and a proprietary trustee of a registrable superannuation entity.
- Kind
- Policy. A policy or procedure for a firm or client.
- Where it applies
- Commonwealth
- AI use
- Yellow You and the tool draft together, with you directing. You check every statement you rely on.
- Law stated as at
- 22 October 2026
- Status
- Maintained. Checked on 22 October 2026 against the 6 authorities it cites, for Commonwealth.
- Version
- 1
- Source
- Written for this library
When to use it
Use when a public company, a proprietary company that has been a large proprietary company, or a proprietary company that is the trustee of a registrable superannuation entity is adopting or replacing its whistleblower policy. The lawyer confirms the company is in one of those classes before the policy is adopted.
Used for these tasks
- Work out which companies must have a whistleblower policy, and from which day
- Issue the eligible-recipient card from the approved whistleblower policy
Each task page says how far AI may help with the task and what the lawyer must review.
How AI may be used
AI may fill the section headings from s 1317AI(5) and the company's own process notes. The lawyer checks that the company is obliged to have the policy and adopts the wording.
AI may
- Place each matter in s 1317AI(5)(a) to (g) under its own heading
- Insert the company's nominated recipients, support steps and investigation steps from notes the lawyer has approved
- List the availability method the company will use for officers and employees
AI must not
- Must not decide whether the company is a public company, a large proprietary company or a registrable-superannuation trustee
- Must not copy paragraphs from Regulatory Guide 270; the guide PDF was not the source of this skeleton
- Must not state that a group policy satisfies each subsidiary, or that the Act requires publication on a website
The lawyer checks
- The company is within s 1317AI(1), (2) or (3), and the start day matches that subsection
- For a proprietary company, the large-proprietary test uses the amounts and employee number prescribed by reg 1.0.02B
- Each matter in s 1317AI(5) is covered, including any matter the regulations prescribe
- The policy is made available to the company's officers and employees
- Tax whistleblower content is checked against Taxation Administration Act Part IVD and the ATO page, not against an unread guide
Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.
Read the full text
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- read the whole precedent, with its drafting notes beside it;
- copy it, or download it as a Word file or Markdown;
- add it to your firm’s knowledge base, so colleagues can find it;
- let the AI tools you connect read it from that knowledge base.
The summary, the law it rests on and the AI-use guidance above stay public. Privacy.
More in Whistleblowing & Public Interest Disclosures
- Eligible-recipient intake record for a corporations or tax disclosure
- Allocation notice and notice to the discloser under the Public Interest Disclosure Act
- Protection-from-detriment checklist for a corporations or public-sector disclosure
- Investigation report for a disclosure allocated under the Public Interest Disclosure Act
- Commonwealth Ombudsman public interest disclosure notification forms
All precedents for Whistleblowing & Public Interest Disclosures · Tasks and AI use in this area