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Whistleblower policy

ASX’s values support a culture that encourages ASX Staff to speak up on matters or conduct that concerns them. ASX also encourages others to speak up about matters of concern about ASX.

About whistleblowing

Whistleblowing refers to a process that allows an eligible whistleblower to raise specific concerns about disclosable matters by ASX Group entities including their officers and employees (“ASX”). These terms are defined in the Whistleblower Protection Policy.

Complaints versus whistleblowing

Making a complaint about ASX by someone who is not an eligible whistleblower is not whistleblowing. Making a complaint to ASX about a listed entity or other issuer whose products are traded on ASX, or about a broker, clearer or other participant in an ASX market or clearing and settlement facility is also not whistleblowing. If you wish to make a complaint such as these you are encouraged to do so via the customer feedback page.

Eligible whistleblower

An eligible whistleblower is:

  • anyone who is or has been an officer or employee of ASX (whether permanent, part-time, fixed-term or temporary), including a contractor, consultant or intern;
  • a current or former supplier to ASX or an employee of such a supplier;
  • an associate of ASX; and
  • a relative, dependent or partner of any individual referred to above.

Disclosable matter

For a complaint or concern to be a considered a disclosable matter, the whistleblower must have reasonable grounds to suspect it involves misconduct or an improper state of affairs or circumstances. This includes any concern about conduct, or the deliberate concealment of conduct, that constitutes an offence against or a contravention of a relevant Commonwealth law. Examples include:

  • financial irregularity by ASX, including a fraud against ASX or a customer or supplier, money laundering or misappropriation of funds by ASX
  • corrupt conduct, including offering or accepting of bribes by ASX
  • criminal conduct, such as theft, dealing in, or use of illicit drugs, violence or threatened violence, and criminal damage against property by ASX
  • failure by ASX to comply with or breach of any legal or regulatory obligation
  • failure by ASX to comply with any other obligation as a market licensee or clearing and settlement facility licensee, as a benchmark administrator or as a holder of an Australian Financial Services Licence
  • unfair or unethical dealing by ASX with a customer (including a participant in an ASX market or clearing and settlement facility or a listed entity or other issuer whose financial products are traded on ASX)
  • unethical or other serious improper conduct, including breaches of ASX policies
  • misconduct, or an improper state of affairs or circumstances by ASX
  • offence against any other law of the Commonwealth that is punishable by imprisonment for a period of 12 months or more
  • conduct by ASX that represents a danger to the public or financial system by ASX
  • ASX engaging in or threatening to engage in detrimental conduct against a person who has made a whistleblowing disclosure or is believed or suspected to have made or be planning to make a whistleblowing disclosure by ASX

ASX's Whistleblower Protection Policy

ASX’s Whistleblower Protection Policy explains the whistleblowing process in detail, including what are disclosable matters, who can qualify as an eligible whistleblower, the eligible recipients to whom a whistleblowing report can be made, and the protections ASX provides for eligible whistleblowers.

If you believe you are an eligible whistleblower and wish to report a disclosable matter, please refer to the Whistleblowing Policy and make your disclosure through one of the channels set out in that policy.