Definition
A formal document that sets out how employees and workers can raise concerns about wrongdoing within the organisation, the protections available to them, and the process the organisation will follow to investigate. It encourages a culture of openness and accountability.
UK Context
While there is no legal requirement to have a written whistleblowing policy, it is strongly recommended by the Financial Conduct Authority, the Charity Commission, and the NHS. The Public Interest Disclosure Act 1998 protects whistleblowers from detrimental treatment. Listed companies must have whistleblowing procedures under the UK Corporate Governance Code.
Best Practices
- Provide multiple reporting channels including an option that bypasses line management, such as a dedicated hotline or external provider
- Make clear that genuine concerns can be raised without fear of retaliation, even if the concern ultimately proves unfounded
- Appoint a senior leader as the whistleblowing champion to oversee the policy and report to the board
Frequently Asked Questions
What is the difference between a grievance and a whistleblowing disclosure?
A grievance relates to the employee's own employment situation (e.g., unfair treatment, pay dispute). A whistleblowing disclosure concerns wider wrongdoing in the public interest (e.g., fraud, safety risks, environmental damage). Different procedures and protections apply to each.
Who can make a whistleblowing disclosure?
Protection extends to employees, workers, agency workers, trainees, and former employees. It also covers job applicants in the NHS. The disclosure must be made in good faith and in the public interest to an appropriate person or prescribed body.