As we’ve covered before, the KPMG Australia has put whistleblowers in the spotlight.

And it appears it may not be over yet:

• SYDNEY, Aug 14 (Reuters) – “Many, many more” whistleblowers have come forward with reports of misconduct at KPMG Australia, a parliamentary committee probing alleged client data leaks at the firm heard on Friday, raising concerns about a broader pattern of wrongdoing.
• The scandal erupted in March following allegations made by an anonymous whistleblower that KPMG misused confidential client information to bid for audit contracts.
• KPMG initially said the claims were unsubstantiated. But the firm’s CEO, audit boss and chairman have all since resigned, and it has confirmed the misuse of internal documents by staff. 
• At a parliamentary hearing in Canberra, Deborah O’Neill, a Labor party senator who chairs the committee, said more people were reporting similar conduct.
• “There are many, many more who are contacting us and they are talking about a repeat of the same behaviour,” O’Neill said.
• KPMG has acknowledged it mishandled the whistleblower complaint and has launched a fourth internal investigation after previous ones failed to substantiate any wrongdoing.

One wonders whether there should be a secondary term for those who come forward once the safety and effectiveness of doing so has been clearly established – whistle riders for instance. But that aside, the KPMG Australia debacle has put whistleblowers back in the spotlight after a period of relative quiet, at least from a Canadian perspective. Around a decade ago, the Ontario Securities Commission put a lot of resources into this aspect of enforcement, establishing a somewhat portentously named “Office of the Whistleblower” which “accepts tips on possible violations of Ontario securities law, offers protections for individuals who come forward, as well as a reward of up to $5 million for tips that lead to enforcement action.” A 2022 update stated that the program “has attracted high quality tips which have resulted in timely and impactful enforcement action, protecting investors from harm, and have led to awards of over $9 million to whistleblowers.” However, that aspect of the OSC website hasn’t been meaningfully updated since a February 2024 update regarding “an award of CAD $1,500,000 to a whistleblower who provided information which allowed the OSC to act swiftly to protect investors from harm.” A recent Canada-wide regulatory “Year in Review” said the following:

• Several CSA members have whistleblower programs that enable individuals and employees to report possible securities laws violations. These programs offer key protections, including confidentiality, the option to report anonymously and anti-reprisal measures. These innovative programs continue to provide valuable information about complex securities misconduct that may not otherwise have come to light.

It indicates that 714 whistleblower tips were received during 2025 to 2026, but in the absence of any further information on their quality or import, it’s not telling us much. The same document reports that 108 enforcement matters (from all sources) were concluded (a final decision issued or settlement reached) during the year: while such matters typically span more than a single year, the comparison suggests that a great majority of whistleblower tips received don’t ultimately result in major action. That’s as one would expect, given that much of what may seem “wrong” or “unethical” doesn’t necessarily equate to a violation of securities law, or not a sufficiently major one to justify the time and effort of bringing an action.

The very term “whistleblower” seems to me suboptimal, evoking as it does the image of an official announcing to anyone within earshot that something notable has happened. It’s only fair to posit, noting the relative numbers above, that a sizeable portion of whistleblowing, as with any other human activity, is based in misunderstanding, error, or less savoury motives (grudges, personal antipathies). It seems appropriate to point out also that the effective functioning of a corporate environment inherently depends to some degree on accepting the preexisting precepts and structure: a corporate culture continually interrupted by “whistles” would rapidly become dysfunctional. All of which is only to say that a certain degree of caution and occasional missteps in dealing with seeming whistleblowers are understandable. But of course, KPMG Australia isn’t some untutored enterprise groping around in the relative darkness, but a self-proclaimed expert in such matters. The website continues to advertise a Regulation and Compliance offering in the following terms:

• In an era of intensifying regulatory scrutiny and rising stakeholder expectations, organizations face mounting pressure to demonstrate robust compliance and governance. Our Regulation and Compliance offering empowers businesses to stay ahead of regulatory change, respond effectively to enforcement actions and build resilient compliance frameworks that protect reputation and drive long-term value.

It’s hard to have much sympathy for a firm that expected (and seemingly still does) to be taken seriously as a purveyor of highly-paid advice on such matters, while apparently exempting itself from big chunks of what it might have prescribed…

The opinions expressed are solely those of the author.