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
- When setting up the complaint procedures.
- At the annual policy review.
- When changing the hotline provider.
What’s inside
- Purpose and what to report
- Channels table with anonymity
- Retaliation and confidentiality
- Handling steps with responsible roles and timings
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.
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.
Related templates
- Whistleblower Complaint Log
- Investigation Report Template
- Audit Committee Charter
- Fraud Risk Assessment Worksheet
Last updated 11/05/2026. All free templates.