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Implementing effective whistleblowing procedures

Author: David Lewis


  • Legislation protects workers who make a qualifying disclosure to a specified recipient, but most employers' arrangements enable individuals to raise concerns about a broader range of issues. (See What is whistleblowing?)
  • Having effective arrangements for reporting concerns about wrongdoing is likely to encourage the supply of information about organisational problems, deter external disclosures and help the employer to demonstrate that it had adequate procedures in place should it be investigated for bribery. (See The benefits of whistleblowing)
  • Employers should create a culture where disclosers feel confident that their concerns will be dealt with appropriately and do not fear retaliation. Support from senior management for the organisation's whistleblowing arrangements is vital to creating such a culture. (See Creating a culture of openness)
  • Employers should consult recognised trade unions about the whistleblowing policy and procedure and ensure that workers can identify the policy easily. (See Accessibility of the whistleblowing policy and procedure)
  • The whistleblowing policy and procedure should set out the principles on which it is based; who can invoke it; the types of wrongdoing that should be reported; and the amount of evidence that a discloser should have before raising a concern. (See The content of the whistleblowing policy and procedure)
  • Workers should be encouraged to raise concerns about wrongdoing with their line manager, but employers should make alternative reporting procedures available too. (See The recipients of concerns)
  • Employers should keep a central record of disclosures that are made through the whistleblowing policy and procedure. (See Records)
  • Employers should explain that they will maintain confidentiality, as far as possible, where a worker makes a disclosure, but that confidentiality cannot be guaranteed. Anonymous reporting is not ideal, but reports made anonymously should not be ignored. (See Confidentiality and Anonymity)
  • Workers who are considering whether or not to disclose information about wrongdoing should have access to advice about the options available to them. (See Advice)
  • When a disclosure is made the employer should conduct an initial screening process, conduct an investigation if appropriate, provide feedback to the discloser and consider whether or not to notify the alleged wrongdoer of the investigation. (See Investigations)
  • Employers should provide training to all workers to ensure that they are familiar with the organisation's whistleblowing arrangements, and additional training to individuals whom they appoint as recipients and investigators of concerns. (See Training)
  • Protection and support should begin as soon as a report of wrongdoing is received and continue throughout and following the reporting process. (See Protection and support)
  • Regular monitoring and review of the organisation's whistleblowing arrangements will help to ensure that they are working effectively. (See Monitoring and review)