On September 17, ACC and its Australian chapter submitted comments to the Australian Securities and Investments Commission (ASIC) in response to their Consultation paper 321 and Draft Guidance on new requirements regarding organizational whistleblower programs. In its comments, ACC praised ASIC for expressing a preference for internal reporting in whistleblower programs. ACC went on to argue the good practice guidance on roles and responsibilities under a whistleblower policy are overly prescriptive and ASIC should revise the section to be more principles-based. Finally, ACC requested further guidance for in-house counsel who find themselves in the position of a whistleblower.
Click here to view ACC’s letter.