Whistleblower Policy


This policy is founded upon ASHM’s commitment to accountability and transparency.

ASHM is committed to the highest standards of legal, ethical and moral behaviour.

This policy is intended to fulfil ASHM’s obligations under the Corporations ACT,2001; this Act provides legal rights and protections for people who meet the definition of an ‘eligible whistleblower’. ASIC Information Sheet 238 describes who can qualify for protections as a whistleblower under the Corporations Act. This policy also meets the requirements set out in the ASIC Corporations (Whistleblower Policies) Instrument 2019/1146, effective 1 January 2020.

ASHM recognises that people who have a working relationship with ASHM are often the first to realise there may be concerns. However, for fear of appearing disloyal or concern about being victimised or the subject of other reprisals, they may be concerned about reporting this misconduct.

ASHM staff, volunteers, contractors and partners who are aware of possible wrongdoing have a responsibility to disclose that information.


The purpose of this policy is to provide a supportive work-relationship environment where misconduct within or by ASHM can be raised without fear of retribution.

This policy provides guidance in detecting corrupt, illegal or other undesirable conduct. ASHM strongly encourages its stakeholders to speak up if they suspect or witness any matters of concern. ASHM will take all reports made under this policy seriously

This is achieved by:

  • encouraging the reporting of serious misconduct
  • providing protected misconduct reporting alternatives to remove inhibitions that may impede such disclosures
  • establishing fair and impartial procedures that enable:
    • protection for those that make serious misconduct disclosures
    • independent internal inquiry/investigation of disclosures made
    • resolution of the issue(s) identified


Whistleblowing is the disclosure by or for a witness, of actual or suspected misconduct in an organisation that reveals fraud, corruption, illegal activities, gross mismanagement, malpractice or any other serious wrongdoing.

Whistle-blower is a person who reports serious misconduct in accordance with this policy.

An Eligible Whistle-blower can be all current and former partners, directors, officers, employees,  contractors, suppliers (or their employee or subcontractor), course and conference attendees and speakers, interns and volunteers.

Misconduct includes behaviour that is:

  • is fraudulent, corrupt or illegal
  • is unethical, such as acting dishonestly; altering company records; wilfully making false entries in official records; engaging in questionable accounting practices; or wilfully breaching ASHM’s code of conduct or the ACFID Code of Conduct
  • is potentially damaging to ASHM, such as maladministration
  • is seriously harmful or potentially seriously harmful to an ASHM employee or volunteer such as deliberate unsafe work practice or wilful disregard to the safety of others in the workplace
  • may cause serious financial or non-financial loss to ASHM; or damage its reputation; or be otherwise seriously contrary to ASHM Whistle-blowing policy
  • involves any other kind of serious impropriety including retaliatory action against a whistle-blower for having made or being suspected of making, a wrongdoing disclosure


This policy is intended to cover serious concerns that could have a large potential impact on ASHM, and it is differentiated from the normal feedback and grievance channels available to employees. Serious concerns covered by the policy could include actions that:

  • may lead to incorrect financial reporting
  • are unlawful
  • are not in line with ASHM policy or its code of conduct
  • otherwise amount to serious improper conduct

For the purpose of this policy, reportable conduct does not include personal work-related grievances. Personal work-related grievances are managed in accordance with ASHM’s Staff Grievance Policy.

All complaints and reports of wrongdoing or misconduct made under this policy must be documented.

No person should be personally disadvantaged for reporting a wrongdoing. Not only may this misconduct be illegal, but it may directly oppose the values and mission of ASHM.

ASHM is committed to maintaining an environment where legitimate concerns are able to be reported without fear of retaliatory action or retribution.

When a person makes such a disclosure they are entitled to expect that a fair and impartial investigation will ensue after a report has been made and:

  • their identity remains confidential at all times to the extent permitted by law or is practical in the circumstances,
  • they will be protected from reprisal, harassment or victimisation for making the report,
  • should retaliation occur for having made the disclosure then ASHM will treat it as serious wrongdoing under this Policy.

The policy will be published in the ASHM website.


ASHM Board – Approved November 2023

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