Comprehensive guidelines

Whistleblowing arrangements code of practice: Publicly available specification 1998:2008. British Standards Institute (BSI).  

The BSI Whistleblowing Arrangements Code of Practice is an essential and comprehensive resource for any organisation considering their whistleblowing policies, drawing together both conceptual analysis of whistleblowing and concrete instructions for organisations.   

The introduction tackles preliminary issues surrounding a whistleblowing mechanism, including: the risks of ineffective arrangements, the distinction between whistleblowing and grievances, applicable national law and the differing needs of organisations of different sizes. Sections 1-3 deal with preliminary issues: clarifying the guide’s scope as applying to private, public and voluntary sector organisations, defining key terms and addressing key issues to consider. Sections 4-6 then cover practical recommendations for the introduction and maintenance of a whistleblowing scheme, as well as a review and evaluation framework (an evaluation checklist is provided in the final section).  

Notably, the guide discusses the merits and drawbacks of using the word “whistleblowing” when referring to reporting mechanisms. It also advocates for open whistleblowing (when a concern is raised openly) to be the default mechanism within organisations, although it recognises the possible limitations to this.  

International Chamber of Commerce guidelines on whistleblowing. International Chamber of Commerce (ICC). 2008.  

The ICC guidelines on whistleblowing put forward practical steps for companies to establish and maintain internal whistleblowing mechanisms, based on the experiences of ICC member companies across a variety of sectors and jurisdictions. Starting from the preposition that it is in the best interest of the firm itself to establish reporting mechanisms, the ICC recommendations claim to be formulated by considering the criticisms made by certain countries of some aspects of a whistleblowing system. It also serves as a useful reference point for relevant international conventions and national legislation in the US, UK and France (note: the information on French law is outdated) covering whistleblowing.  

A good practice guide to whistleblowing policies. A/P Mak Yuen Teen, PhD. Certified Practicing Accountants Australia. 2007. http://governanceforstakeholde...  

This good practice guide from Australia’s Certified Practicing Accountants body focuses on whistleblowing policies in the context of corporate governance and was created in consultation with 20 of Australia’s leading corporations, regulatory bodies, individual members and organisations of various sizes. The publication refers to examples and laws from the US, UK and Australia, and is sufficiently broad in scope to be useful to a wide private sector readership. The guide is structured around key questions or prompts, such as: “who to make the disclosure to?” “What are the types of breaches that can be reported?” “How can the disclosure be made?” and sets out quite concrete advice in the form of answers to these questions. Similar to the BSI Code of Practice, some of its notable recommendations are a differentiated whistleblowing policy to the normal grievance and feedback channels and a whistleblowing hotline rather than an internal complaints channel.

OECD guidelines for multinational enterprises. 2011.  

The OECD guidelines for multinational enterprises provide non-binding recommendations by governments to multinational enterprises operating in or originating from signatory countries. The guidelines are a key multilateral comprehensive code of conduct that governments have committed to promoting (through, for example, the establishment of “national contact points” consisting of senior representatives from ministries, government officials or a group of independent experts responsible for undertaking promotional activities).  

The guidelines contain general details on responsible business conduct and a clause that states: “safeguards to protect bona fide ‘whistle-blowing’ activities are also recommended, including protection of employees who, in the absence of timely remedial action or in the face of reasonable risk of negative employment action, report practices that contravene the law to the competent public authorities’.  

Speak up for a healthy NHS: How to implement and review whistleblowing arrangements in your organisation. Public Concern at Work, United Kingdom National Health Service. 2010.  

This guide was commissioned by the National Health Service (NHS) Social Partnership Forum and written by Public Concern at Work (PCaW). It outlines the importance of whistleblowing, what is expected of NHS boards and their executives, and the NHS organisation employers can expect from PCaW and the Department of Health, containing case studies and a model policy. Importantly, it considers whistleblowing from the perspective of helping to “improve patient safety and minimise harm to patients”.  

Despite being directed at the health sector, many of the recommendations echo those of more general guidelines (for example: support from leadership, promotion and communication, auditing and review of procedures and the right to seek independent advice). The model policy is specific to NHS organisations.    

The Whistleblowing Commission: Code of Practice. Public Concern at Work. 2013.  

UK-based whistleblowing charity Public Concern at Work set up a whistleblowing commission in 2013 to focus on workplace whistleblowing, which recommended the creation of a statutory code of practice to assist employers, workers and their representatives in addressing whistleblowing concerns. The code of practice is rooted in (UK) statute and, as such, can be taken into account in court cases and by regulators. It sets out 15 recommendations for workplace whistleblowing procedures, including the following key recommendations: delegation of responsibility to specific individuals for whistleblowing arrangements, confidentiality assurance where requested, assurance to staff about protection from reprisal, greater oversight of whistleblowing arrangements by non-executive directors (or equivalent) and the review of effectiveness of arrangements and publication of key data.  

Striking a balance: Whistleblowing arrangements as part of a speak up strategy. PwC. 2013.  

PwC developed this guide after consulting with their main clients. It is aimed at business leaders and covers the legal landscape affecting whistleblowing primarily in the US, UK and EU. It offers guidance in five key steps for organisations to develop a whistleblowing policy: gaining top level commitment, developing a whistleblowing policy, designing whistleblowing reporting mechanisms, embedding a whistleblowing programme and reporting, monitoring and evaluating whistleblowing arrangements. It also includes in the appendix the results of PwC's Fraud Academy survey on whistleblowing, undertaken in 2010 by industry experts and organisations.  

Whistling while they work: A good-practice guide for managing internal reporting of wrongdoing in public sector organisations. Roberts, Brown, Olsen. 2011.  

This guide for managing internal reporting in public sector organisations was produced with data collected from over 300 Australian national, state and local agencies, including individual survey responses from approximately 10,000 public sector employees, managers and persons involved in the management or investigation of internal reporting. Aside from the more recent follow-up study, Whistling while they work 2, this is one of the only guides based on large-scale research into whistleblowing best practices and which forms recommendations based on the results of this research. It can therefore be considered essential reading for all organisations looking for information on the subject.  

The guide breaks down its recommendations for whistleblowing mechanism best practices into five main categories: organisational commitment to good management of whistleblowing; facilitating reporting (reporting pathways and procedures); assessment and investigation of reports; internal witness support and protection; and an integrated organisational approach. Moreover, employers can use the checklists provided to evaluate the policies of their own organisation.  

First to know. Trace International. 2004.  

TRACE is an international non-profit business association that works with companies to help them meet their anti-bribery compliance obligations. This resource puts together guidelines to establish an internal reporting mechanism for general corporate wrongdoing, based on the findings of a study of 30 companies across 10 countries. Despite being published in 2004, the guide still provides relevant and useful information to all types of organisations.  

This guide briefly introduces the key laws governing whistleblowing in the UK and the US, and gives examples of challenges and success stories, illustrated with case studies from the participating companies. The guide then identifies 10 key components of a robust internal reporting programme: communication, accessibility, cultural appropriateness, universality, confidentiality and anonymity, screening, data collection, remedial action and feedback, management visibility, employee protection and external communication to shareholders on actions taken and results achieved.  

Linee guida per la predisposizione di procedure in materia di whistleblowing. Transparency International Italy. 2016. (Italian)  

Transparency International Italy developed guidelines for the application of effective whistleblowing mechanisms in companies and organisations, published with support from global law firm DLA Piper and the Hermes Centre for Transparency and Digital Human Rights. The guidelines include a summary of international and Italian relevant law before moving on to make recommendations to be implemented internally by organisations, stating that their applicability is intended for enterprises and organisations of all sizes. It identifies as key elements of a whistleblowing policy: clear written procedure, commitment from leadership, assurance of confidentiality and provision of anonymity when reporting, clear distinction of grievances from whistleblowing, feedback to and protection of reporters, multiple reporting channels and training of staff and employers. It also contains useful guidance on how to make a report (for example, useful details or information to include) and how to evaluate a report.  

Whistleblowing: An effective tool in the fight against corruption. Transparency International policy position. 2010.  

This policy position provides a set of recommendations derived from Transparency International’s draft guiding principles for drafting whistleblowing legislation, while simultaneously recognising that effective follow-up mechanisms in organisations must be established to complement any existing legal framework. The policy paper outlines key steps organisations can take to ensure an effective whistleblowing policy: transparent and robust internal policies; the assurance of confidentiality when reporting; thorough investigation in response to reports; and staff consultation and training during the design and implementation process.

Whistleblowing: Guidance for employers and code of practice. UK Government, Department for Business Innovation & Skills. 2015.  

The guidance and code of practice for employers, issued by the UK Government Department for Business Innovation and Skills is designed to help employers understand the law relating to whistleblowing, establish a whistleblowing policy and recognise the benefits whistleblowing can bring to an organisation. Although it contains references to UK-specific elements of whistleblowing, it is sufficiently general and can be read by organisations in any sector. The guide contains useful definitions of terms such as whistleblowing, disclosure, grievance, confidentiality and anonymity. It also identifies some general responsibilities of an employer when setting up a whistleblowing mechanism, such as training, resolution of wrongdoing, and fostering an open and supportive culture. It concludes with a whistleblowing code of practice with a concise list of best practices for employers to adopt.   

Best practices for protecting whistleblowers and preventing and addressing retaliation. United States Department of Labor (Occupational Safety and Health Administration). 2015.  

This guide is applicable to public, private and non-profit organisations, with special considerations in many sections for small businesses and statute (US) or industry-specific considerations. The guide focuses on how to prevent and remedy retaliation after an employee has spoken up. The publication has six sections and dos and don'ts for each. This resource is particularly useful for SMEs and organisations operating within the US.

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