The answer to this is yes. Mr. Walbourne had no choice but to report to nobody else but the minister the allegations made to him by the two complainants. He had also no authority to investigate the matter, so the whole thing was passed on to the minister.
The minister had fundamentally two duties. One was to investigate. He had the tools to do so by section 45 of the National Defence Act. The second duty was to report to PCO, because in fact allegations were made against somebody with a Governor in Council appointment.
As far as I understand, the minister elected not to investigate and not to appoint anybody to do so, but he could have.