Does your company have whistleblowing arrangements in place?

Question collaborator: Public Concern at Work


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GOOD Answers

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OKAY Answers

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Every employer faces the risk that something will go badly wrong in their organisation and ought to welcome the opportunity to address it as early as possible. The individuals often best placed to speak up about these risks, or ‘blow the whistle’, are usually those who work in the organisation, yet they often have the most to lose if they do. ‘Whistleblowing’ refers to raising concerns about wrongdoing within an organisation. The concern must be a genuine one about a crime, criminal offence, miscarriage of justice, dangers to health and safety or to the environment, or the covering up or attempt to cover up of any of these. It’s not the same as making a complaint which usually relates to one individual personally. Whistleblowers have legal protection in the UK under the Public Interest Disclosure Act 1998.

Whistleblowing arrangements are a vital component of good governance and risk management in any organisation or industry. Effective whistleblowing can ensure that disaster is averted, costly legal claims are avoided and reputation is preserved. Benefits go beyond detecting wrongdoing and include deterring malpractice and improving standards and quality. A responsible approach to whistleblowing also helps an organisation to promote a healthy workplace culture built on openness and accountability.

A Code of Practice (CoP) has been developed by the Whistleblowing Commission. The CoP provides practical guidance to employers, workers and their representatives and sets out recommendations for raising, handling, training and reviewing whistleblowing in the workplace. It can be viewed on Public Concern at Work’s website. They have clearly outlined what they believe constitutes an effective whistleblowing policy.

To be considered effective, a whistleblowing policy should have a clear, well publicised written procedure, along with a clear outline of who informants can report to, including relevant external bodies and key, nominated individuals within the organisation. Staff should routinely be made aware of the policy, and if it is working effectively staff confidence levels in the process should be high. Assurances should be made that no detriment will come to informants who provide information in good faith. Further, informants’ confidentiality should be assured and protected, and procedures and timescales should be made clear from the outset. Companies that have effective whistleblowing policies should make clear efforts to ensure that their procedures are effective by, for instance, carrying out regular audits, keeping adequate records, providing training and giving feedback to informants on the progress of the concerns they have raised.

Public Concern at Work emphasises the importance of confidentiality, rather than anonymity with whistleblowing. When a concern is raised confidentially, the whistleblower gives their identity on the understanding that this information will not be revealed without their consent. An anonymous whistleblower does not give their identity at any point. The advantage of confidential complaints is that the whistleblower can be consulted during the investigation process, and can receive feedback on how the concern was dealt with, and, crucially, that the organisation can protect the whistleblower. Furthermore, having confidential complaints rather than anonymous ones means the business is able to conduct audits on the process and report on its own whistleblowing process.

Ideally, informants should feel able to report concerns openly. Openness makes it easier for the employer to assess the issue, work out how to investigate the matter and obtain more information. A ‘speak up culture’ is most conducive to staff feeling comfortable expressing their concerns and feeling that they are listened to. This requires staff to have confidence that they won’t be penalised or treated badly for raising concerns and that it won’t harm their relationships with their colleagues or managers, or affect their career progression.


'Informants' may be a) employees with the duty to inform (their disclosure is not a matter of ethics but a legal obligation), or b) those with personal involvement in the wrongdoing who disclose information in order to justify their role or reduce their liability.


A 'complaint' is seeking redress or justice by an individual who has personally been poorly treated, perhaps through a breach of their individual employment rights or bullying within the workplace. The complainant has a vested interest in the outcome of the complaint - and therefore is usually expected to be able to prove their case.

Genuine concerns

A worker has a 'genuine concern' when she or he has a reasonable belief that their disclosure is in the public interest, even if the concern is later disproved.


A worker receives 'anonymity' when they do not give their identity when reporting a concern.


'Confidentiality' is given to a worker who gives their identity on the condition that it will not be revealed without their consent


A worker who suffers a 'detriment' as a result of raising a concern is subjected to a disadvantage by their employer or co-workers. This could include, but is not limited to:
● Failure to promote
● Denial of training
● Closer monitoring
● Ostracism
● Blocking access to resources
● Unrequested re-assignment or re-location
● Demotion
● Suspension
● Disciplinary sanction
● Bullying or harassment
● Victimisation
● Dismissal
● Failure to provide an appropriate reference
● Failing to investigate a subsequent concern.


A 'worker' in the context of whistleblowing is not limited to those employed by the company in question, but extends to:
● Contractors
● Agency workers and individuals supplied via an intermediary
● Non-employees undergoing training or work experience as part of a training course, otherwise than at an educational establishment
● Self-employed doctors, dentists, ophthalmologists and pharmacists in the NHS
● Police officers
● Student nurses and student midwives.

Answering YES

All Businesses MUST

Describe their practices and policies to encourage and address employee concerns about wrongdoing in the workplace

Confirm that employees are not penalised for such actions, describe how this is ensured, and what procedures for redress are in place if detriments do happen

Describe how confidentiality is protected

All Businesses MAY

Provide examples, e.g. describe some concerns that have been raised by whistleblowers and subsequently resolved

Explain how they encourage employees’ participation in raising issues of concern

Describe training provided to staff

Provide previous annual reports or data regarding whistleblowing policies, if available

Describe who is covered by this policy, e.g. contractors, employees, volunteers

Explain how they assess effectiveness of the policy within the organisation

Explain how they ensure staff are aware of the policy

Large and Multinational Corporations (MNCs) MUST

Explain if their practices differ from one country to another

Justify these differences, if any

Answering NO

All Businesses MUST

Explain why they do not or cannot answer YES to this question, listing the business reasons, any mitigating circumstances or other reasons that apply

All Businesses MAY

List any practices that are relevant, but not sufficient to answer YES

Mention any future intentions regarding this issue

DON'T KNOW is not a permissible answer to this question

NOT APPLICABLE is not a permissible answer to this question

Version 3

To receive a score of 'Excellent'

Clear commitment to whistleblowing process with leadership at every level of management. There is a rigorous, effective whistleblowing policy in place, which effectively protects and supports whistleblowers

Examples of policy and practice which may support the EXCELLENT statement:

  1. Clear policy in place that is transparent and made available to all staff
  2. Process of whistleblowing policy is made transparent to all members of staff
  3. A secure ‘speak up’ culture with high levels of employee awareness, trust and confidence to raise concerns
  4. Increasing numbers of concerns being raised openly or confidentially and corresponding reduction in anonymous concerns
  5. Effective provisions made to protect confidentiality of informants
  6. Focused campaigns around key risks based on own audit, review and research
  7. Regular refreshment and clarification of whistleblowing messages to employees
  8. Comprehensive and well established training across the entire organisation to both managers and staff
  9. Examples of early detection of fraud, malpractice or aversion of harm as the result of a member of staff blowing the whistle
  10. Examples of organisational improvement as a result of whistleblowing
  11. Communication of such positive outcomes across the organisation
  12. Evidence that feedback to the individual whistleblower has been consistently provided in a timely manner
  13. Concerns are tracked from them being made to their resolution. This tracking is highly effective, so concerns do not ‘get lost’ and are not ignored
  14. Positive feedback from whistleblowers
  15. No detriments suffered by informants, with clear guidelines and safeguards in place to prevent or redress any incidents of detriment
  16. Support for prospective, current and previous informants, including access to external advice and support
  17. Regular audits of procedures and satisfaction levels
  18. Annual reports published and/or accurate records maintained to ensure high quality and to track progress of complaints
  19. Company is considered example by other organisations, contributes to campaigns and/or advocates for high standards across the industry/sector
  20. Policies in place across all territories qualify as excellent
  21. Policies are continuously reviewed and improved
To receive a score of 'Good'

Obvious commitment and leadership from management. Some examples of positive outcomes as a result of information gathered, and whistleblowers are protected, though may choose to remain anonymous

Examples of policy and practice which may support the GOOD statement:

  1. Comprehensive policy in place that exceeds minimum requirements
  2. A ‘speak up’ culture that makes it safe to raise concerns
  3. Good employee awareness, trust and confidence to raise concerns
  4. Clear and easily usable practices and policies disseminated within the business
  5. Consistent enforcement of whistleblower policies by managers
  6. Training for managers on handling whistleblowing
  7. Training for staff around whistleblowing
  8. Employee engagement encouraged and facilitated at every level of the organisation
  9. Keeping the issue live through reinforcement and messages
  10. Communicating the outcome of whistleblowers’ efforts across the organisation
  11. Concerns are tracked from their being made to their resolution, meaning that they rarely ‘get lost’ in the system
  12. Procedures and results are monitored, and performance regularly measures up to stated policies and associated goals
  13. Policies differ across countries, but while there is some variation, all qualify as either GOOD or EXCELLENT
  14. Supports external efforts to improve best practice or policies, eg. through lobbying, but does not take leadership role
To receive a score of 'Okay'

Company has a whistleblowing policy but the quality, implementation or results of the policy are inconsistent OR this issue is not material or applicable to the business

Examples of policy and practice which may support the OKAY statement:

  1. Ad hoc steps evident to deal with employee concerns about wrongdoing in the workplace
  2. Some employee engagement, such as guidelines, training
  3. Respect for confidentiality evident
  4. Feedback to whistleblowers is inadequate
  5. Reporting on concerns is ad hoc
  6. There are strategies in place to improve the systems that handle concerns in the future
  7. Structures are not in place to track concerns, meaning that sometimes, concerns ‘get lost’
  8. Policies differ across countries and effectiveness is highly dependent on national laws, meeting minimum regulations only
  9. Recognises that performance can improve and plans to do so
To receive a score of 'Poor'

The business acknowledges performance below expectations or no action evident

Examples of policy and practice which may support the POOR statement:

  1. No evidence of practices or policies to address employee concerns about wrongdoing in the workplace
  2. Understanding of issue and risks not evident, statement of future intent to improve
  3. Company discourages, whether actively or passively, whistleblowing and/or fails to adequately protect whistleblowers from detriments
  4. Company attempts to adversely influence whistleblowing legislation
  5. Company discourages whistleblowing and adequate whistleblowing policies in its clients, suppliers and competitors
  6. Company knowingly continues harmful practices that whistleblowers have brought to light