Free Word template · Exchange Act Rule 10A-3(b)(3)

Whistleblower Procedures and Policy

The policy lets employees and others report concerns about accounting, internal accounting controls, auditing matters, fraud and other misconduct, in confidence and without fear of retaliation. For a listed issuer the audit committee must have procedures for receiving, retaining and treating such complaints and for confidential, anonymous submissions by employees (Exchange Act Rule 10A-3(b)(3)).

Standard
Exchange Act Rule 10A-3(b)(3)
Format
Word (.docx)
Cost
Free
Access
No sign-up

What it is

The policy lets employees and others report concerns about accounting, internal accounting controls, auditing matters, fraud and other misconduct, in confidence and without fear of retaliation. For a listed issuer the audit committee must have procedures for receiving, retaining and treating such complaints and for confidential, anonymous submissions by employees (Exchange Act Rule 10A-3(b)(3)).

It covers what to report, the channels, protection from retaliation, confidentiality, a step table with timings, retention and reporting to the committee.

When to use it

What’s inside

Standard cited

This template follows Exchange Act Rule 10A-3(b)(3). It is written in our own words, except for phrases the standard requires the document to contain, with [bracketed placeholders] for client details, amounts in USD and dates as MM/DD/YYYY. Check it against the current standard and your firm’s methodology before use.

Download free Word template (.docx)

Questions

Does the policy have to allow anonymous reports?

For listed issuers, Rule 10A-3(b)(3) requires a procedure for the confidential, anonymous submission by employees of concerns about questionable accounting or auditing matters. Other entities should do the same as good practice.

Should counsel review it?

Yes. Employment law, state law and other whistleblower rules may apply. This is a draft and not legal advice.

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Last updated 11/05/2026. All free templates.