Deloitte’s Whistleblowing Service
Introducing Deloitte HALO
Deloitte’s whistleblowing team has been serving clients securely and effectively for more than ten years. Deloitte HALO has been specifically designed to meet users’ needs as well as manage evolving legislation.
Whistleblowers may have important information your organisation needs today – information about misconduct like fraud; corruption; breach of policies or emerging threats. Whistleblowing information security and whistleblower wellbeing will be a regulatory obligation from 2019 for all Australian organisations with more than 50 employees. Managing disclosures incorrectly / non-compliantly with the new laws can trigger fines for managers of up to $200,000 and $1M for organisations.
Deloitte’s whistleblowing team has been serving clients securely and effectively for more than ten years. The service is offered both online and as a call centre – where those with information can lodge a disclosure 24/7 - either confidentially or totally anonymously from anywhere around the world. Deloitte HALO can be promoted to potential whistleblowers (inside an organisation or to the wider public externally) as either a Deloitte service or customised to complement any organisation’s own brand, culture, size or footprint.
This service is powered by Deloitte’s HALO platform – designed specifically to meet users’ needs as well as evolving legislation. Using HALO, whistleblowers are carefully guided through the process to ensure they feel supported and can independently access updates on the case they lodge anytime.
About Deloitte Halo
Organisations we serve also choose Halo to help strengthen their management accountability and oversight for resolving issues reported to them. Organisations that use our service access Halo to work with their conduct cases via a clear dashboard offering them proactive case prompts / reminders and visual notifications of cases’ progression; analytics search capability and flexible notes fields for use by investigators or storage of evidence supplied by whistleblowers.
Inside Halo, all users are further protected as Deloitte analysts carefully review and moderate all communication on the Halo platform between the organisation and their whistleblowers – preserving anonymity if the whistleblower requests this. Our teams are dedicated specialists working from secure premises on stand-alone, secure, onshore IT infrastructure that is stress tested and continuously monitored.
Apart from managing whistleblowing disclosures, Halo can also house and manage complaints as cases. As Royal Commissions have suggested, organisations find it hard to defend their diligence unless they can attest to a comprehensive, up-to-date, detailed and integrated picture of all reported misconduct and allegations under management (whistleblowing disclosures; formal complaints and informally escalated concerns) that can be tracked for momentum and governance oversight.
Update on the Draft Bill’s Progress
The revised draft of the amendments to the Corporations Act 9.4AAA addressing whistleblower protection has been in draft as a Bill since 2017. This draft was further amended on 6 December 2018. Industry interest around this change is high because failure to meet the proposed regulatory obligations on whistleblower anonymity can trigger penalties of $200K per manager and $1M for organisations. Whilst many firms are promoting urgency around the proposed changes, the final text of the Bill will not be available until it has passed a third reading and achieves Royal Assent. Until then, organisations will not be able to confidently develop or change existing whistleblowing policies, procedures or training. But, in the interim, it is useful to update insight about what is proposed and the likely timeline for change.
The third reading of the draft Bill is likely to be scheduled for the next sitting of both Houses of Parliament (either 12-14 Feb or 18-21 Feb 2019). This is where the House of Representatives debates the draft Bill and potentially votes to endorse it for Royal Assert making it law.
The amended draft has changed the implementation date from July 2018 to the end of the second quarter after the Bill achieves Royal Assent – in plain terms, that will mean organisations will need to be complaint with the new legislation from, at the earliest, September 2019.
December 2018 – Amendments to the Draft Bill (what’s changed)
A clear comparison table of the December 2018 amendments is found on pages 7-8 of the Treasury Laws Amendment (enhancing whistleblower protections) Bill 2017.
Treasury Laws Amendment (enhancing whistleblower protections) Bill 2017
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