Whistleblower policy, Ondray Foods

Whistleblower policy template with an eligible recipients table

A whistleblower policy has to tell people who can speak up, what qualifies, exactly who they can tell, and how they are protected, in terms that match Part 9.4AAA of the Corporations Act. This five page Australian policy for a food manufacturer with 150 staff does that with a six row eligible recipients table, a timed investigation path and a quarterly board report.

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Ondray Foods Pty Ltd
5 April 2027

Whistleblower policy

How to speak up about wrongdoing, who to tell, and how the law and the company protect you.

Prepared by
General Counsel
Date
5 April 2027
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1
Purpose
Ondray Foods makes chilled meals and sauces at two plants for supermarkets, with about 150 employees and revenue of $62 million. As a large proprietary company it must have a whistleblower policy under section 1317AI of the Corporations Act 2001. More importantly, the company wants to hear about wrongdoing early, from the people who see it first. This policy explains who can speak up, about what, to whom, and the protections that apply under Part 9.4AAA of the Act.
2
Who can make a disclosure
You are an eligible whistleblower if you are, or have been, any of the following:
an officer or employee of Ondray Foods, including casual, part time and fixed term staff
a supplier of goods or services to Ondray Foods, such as a farmer, a freight company or a cleaning contractor, or an employee of that supplier
an associate of the company, such as a director of a related company
a relative, spouse or dependant of any of the people above
3
What can be reported
A disclosure qualifies for protection if you have reasonable grounds to suspect misconduct or an improper state of affairs in relation to Ondray Foods. You do not need proof, and a disclosure still qualifies if it turns out to be wrong, as long as it was not knowingly false. Examples at Ondray Foods include:
falsifying food safety, temperature or allergen records, or releasing product that failed testing
fraud, theft, or false invoices from suppliers
paying or accepting a bribe, for example to win or keep a supermarket contract
agreeing prices or splitting customers with a competitor
tax evasion or misleading the Australian Taxation Office
conduct that is an offence punishable by 12 months or more in prison, or that is a danger to the public
Personal work related grievances are handled differently
A complaint only about your own employment, such as a pay dispute, a transfer, a performance review or a conflict with a colleague, is generally not protected under this policy (section 1317AADA). Raise it under the grievance policy instead. It may still qualify if it also involves wrongdoing that affects others, or if you suffered detriment for speaking up.
4
Eligible recipients
To be protected, a disclosure must go to an eligible recipient. You can choose any recipient below, and you can stay anonymous with all of them.
Recipient
At Ondray Foods
How to reach them
Whistleblower protection officer
General Counsel
Direct line, email or in person at either plant
Officers and senior managers
Any director, the chief executive or the chief financial officer
In person or by email marked confidential
Independent hotline
External provider, not company staff
Phone or online form at any hour; anonymous if you choose
Auditor
The company's external audit firm
The audit partner, by email or post
Regulators
ASIC or APRA; the ATO for tax matters
Their published whistleblower channels
Your lawyer
A legal practitioner you choose
For advice about the whistleblower laws
Public interest and emergency disclosures
In limited cases you may go to a journalist or a member of parliament (section 1317AAD). A public interest disclosure needs an earlier disclosure to ASIC, APRA or another prescribed body, at least 90 days to have passed with no reasonable grounds to think action is being taken, and written notice to that body first. An emergency disclosure needs a substantial and imminent danger to someone's health or safety or to the environment, and written notice first. Get legal advice before relying on either.
5
Making a disclosure
A disclosure can be made by phone, in person, in writing or through the hotline form. It helps the investigation if it includes:
what happened, where and when, as precisely as you can
who was involved, and who else may have seen it
any documents, photos, batch numbers or records that support it, or where they can be found
whether you have raised it before, and with whom
a way to contact you, even an anonymous email address, so the investigator can ask questions
6
Anonymity and confidentiality
You may report anonymously, refuse to answer questions that could identify you, and use a pseudonym. Your identity, and information likely to identify you, will not be disclosed without your consent, except to ASIC, APRA, the Australian Federal Police or a lawyer, as section 1317AAE allows. Investigators may share information needed to investigate, after removing your name and taking reasonable steps to stop you being identified. Records are kept in a restricted file that only the protection officer and the investigator can open.
7
Protection from detriment
Nobody may cause or threaten detriment to you because they believe or suspect you made, or might make, a disclosure (section 1317AC). Detriment includes dismissal, demotion, changed shifts, harassment, damage to reputation and harm to your property. A court can order compensation (section 1317AD), and you are protected from civil, criminal and administrative liability for making the disclosure (section 1317AB), although not for your own part in any misconduct. Practical support from the company includes:
a named contact in the protection officer for the whole process
paid leave, a change of supervisor or a move to the other plant, if you ask for it
free, confidential counselling through the employee assistance program
a check in with you three and six months after the matter closes
8
How a disclosure is handled
Every disclosure follows the same path, with these target times:
Within 2 business days
Acknowledged
Within 5 business days
Assessed as protected or not, and next steps decided
Within 10 business days
Independent investigator appointed
At least every 20 business days
Progress update to the discloser
Target 60 business days
Investigation finished and findings reported
9
Fair treatment of people named
A person named in a disclosure is told about the allegations before any finding is made, and has a fair chance to respond. They also have access to the employee assistance program. No action is taken against them on the disclosure alone; any action follows the investigation findings and the disciplinary policy.
10
Tax matters
Disclosures about the tax affairs of Ondray Foods, such as false GST claims or hiding income, are protected in a similar way under Part IVD of the Taxation Administration Act 1953. They can be made to any eligible recipient in clause 4, to the company's registered tax agent, or directly to the Commissioner of Taxation, and the same confidentiality and support apply.
11
Reporting to the board
The protection officer reports to the Audit and Risk Committee each quarter, and the committee reports to the board. Reports never identify a discloser. Each report covers:
Item
What the committee sees
Volume
Disclosures received, by channel and by plant
Type
Food safety, fraud, bribery, competition, tax, other
Status
Open, closed, and any past the 60 day target with the reason
Outcomes
Substantiated or not, and the actions taken
Detriment
Any complaint of detriment and how it was resolved
12
Access, training and review
This policy is on the staff intranet, in the induction pack, on noticeboards at both plants and on the company website, so former staff and suppliers can find it. Every employee completes whistleblower awareness training at induction, and managers and the eligible recipients complete further training each year on receiving disclosures. General Counsel reviews the policy every two years, and sooner if the law changes, and the board approves any change.

Section by section

What each section is for, so you can keep the ones you need and drop the rest.

Cover
Masthead cover with the company, title and purpose line.
1 to 3. Purpose, who and what
Section 1317AI, eligible whistleblowers and food industry examples, with a grievance callout.
4. Eligible recipients
Six recipients with who they are and how to reach them, plus public interest and emergency rules.
5 and 6. Making a disclosure and confidentiality
What to include and how identity is protected under section 1317AAE.
7. Protection from detriment
Sections 1317AB to 1317AD and four kinds of practical support.
8. How a disclosure is handled
A five step timeline from 2 to 60 business days.
9 to 12. Fairness, tax, board and review
People named, Part IVD tax disclosures, the quarterly board report and two yearly review.

How to adapt this document

First, fill the recipients table with your real people and channels, and make sure at least one is outside management, such as an external hotline. Second, rewrite the examples in clause 3 for your industry; a builder would list falsified compliance certificates, a financial adviser hidden fees. Third, if you are a small proprietary company with no legal duty to have a policy, keep it anyway but shorten clause 11 to a yearly note to the directors, since the legal protections apply to disclosures about you regardless.

Which law the terms follow

The policy follows Part 9.4AAA of the Corporations Act 2001: eligible whistleblowers in section 1317AAA, disclosable matters in 1317AA, eligible recipients in 1317AAC, public interest and emergency disclosures in 1317AAD, confidentiality in 1317AAE, immunities in 1317AB, detriment in 1317AC and compensation in 1317AD. Tax disclosures follow Part IVD of the Taxation Administration Act 1953. ASIC Regulatory Guide 270 describes what the policy must contain.

What makes this document work

Recipients are named, not just categorised

The table turns the Act's categories into people and channels at this company: General Counsel as protection officer, any director or the chief financial officer, an external hotline open at any hour, the audit partner, ASIC, APRA and the ATO, and your own lawyer. A worker on the night shift can see where to go.

Food industry examples make it real

Clause 3 lists wrongdoing a staff member at a chilled meals plant might actually see: falsified temperature or allergen records, product released after failing testing, a bribe to keep a supermarket contract, prices agreed with a competitor. Generic examples like fraud alone leave plant staff unsure.

Every step has a target time

The timeline acknowledges a disclosure within 2 business days, assesses it within 5, appoints an investigator within 10, updates the discloser at least every 20 and targets findings in 60. The board report then shows any case past the 60 day target with the reason.

Questions people ask

Which companies must have a whistleblower policy in Australia?

Public companies, large proprietary companies, and proprietary companies that are trustees of registrable superannuation entities, under section 1317AI of the Corporations Act 2001. A proprietary company is large if it meets two of three tests for the year: consolidated revenue of $50 million or more, gross assets of $25 million or more, or 100 or more employees.

Can a whistleblower stay anonymous and still be protected?

Yes. A disclosure can be anonymous and still qualify, and the discloser can refuse questions that might identify them or use a pseudonym. Giving an anonymous contact method, such as a separate email address, lets the investigator ask follow up questions, which often decides whether a matter can be properly investigated.

Is a complaint about my own pay a whistleblower disclosure?

Usually not. Section 1317AADA excludes personal work related grievances, such as pay disputes, transfers or performance reviews, unless they also involve wider wrongdoing or detriment for speaking up. Those go through the grievance policy, and outside bodies such as the Fair Work Ombudsman remain available for pay and conditions.

What does ASIC expect a whistleblower policy to contain?

ASIC's Regulatory Guide 270 sets out the required content: the protections available, who can receive disclosures, how to make one, how the company supports and protects disclosers, how it investigates, how people named are treated fairly, and how the policy is made available. It also gives good practice guidance on training and reporting.

Can someone go straight to the media?

Only in narrow cases. A public interest disclosure needs an earlier disclosure to ASIC, APRA or a prescribed body, 90 days without reasonable grounds to think action is being taken, and written notice first. An emergency disclosure needs substantial and imminent danger. Going to a journalist outside these rules is generally not protected.

Who should be the whistleblower protection officer?

Someone senior, trusted and independent of the business lines most likely to be reported on, often the general counsel, company secretary or head of risk. They need authority to protect the discloser, for example by moving a supervisor, and a direct line to the audit committee so they can escalate without going through management.

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