The Importance of Noticing What is Not Being Said

Looking is not the same as seeing. An organisation can review its reports, hold meetings, and still not have visibility.

Visibility requires leaders to notice what is not being said, ask why, and consider whether that silence is reassuring or an indication of something else.

Listening is one way organisations detect emerging concerns, but it is only effective when people are willing and able to share what they know.

In its first benchmarking exercise of whistleblower practices across corporate Australia, ASIC surveyed 134 entities across 18 industries. It found that 58 per cent had not sought feedback from employees and 30 per cent did not regularly review the effectiveness of their program. ASIC also noted that the responses were self-reported and had not been independently audited.¹

A quiet channel can have at least four different explanations:

1. Concerns are being raised and resolved early.
2. People do not trust the channel.
3. No effective reporting mechanism exists.
4. Reports are being received but not properly reviewed.

The PowerIntent Framework® applies a visibility lens to help leaders consider which explanation may be operating within their organisation.

Accountability and responsibility

Where responsibility is unclear, accountability is weakened.

Accountability establishes who is answerable for a decision, action or outcome, not only when something goes wrong, but also when it goes right.

For regulated financial entities, aspects of this are now codified.

A named person, a defined set of responsibilities, and remuneration that is deferred and reduced where obligations are not met.

All of this ultimately connects to the quality of information reaching those charged with governance. When that information is incomplete, filtered or unexpectedly absent, boards have a responsibility to ask what may be missing and why.

The PowerIntent Framework® helps boards examine what silence may mean, rather than assuming it provides reassurance.

¹ ASIC, Report 827 Insights from the ASIC Whistleblower Questionnaire: July 2024 to June 2025 (4 December 2025).