Organisation size

There is no one-size-fits-all whistleblowing policy. Small and medium-sized organisations (SMEs) do not have structures or resources comparable to large organisations and, as such, will have different needs and limitations when implementing a whistleblowing policy.

Some challenges may include insufficient resources to set up a specific team or individual dedicated to handling complaints, difficulties in maintaining confidentiality and a high burden of responsibility placed on one person (particularly in a management role). One study identified that 35.6 per cent of small organisations responded that they have no particular system in place or only an ad-hoc system as needed, when concerns are raised.[1]

Best practices for protecting whistleblowers issued by the US Department of Labor (Occupational Safety and Health Administration) are a good reference for SMEs as each recommendation is adapted for organisation size. The British Standards Institute guidelines also consider the challenges of SMEs and recommends that they pay special attention to:  

  • the difference between a whistleblowing concern and a private complaint
  • that employees and managers understand their role and that managers should not feel undermined if they are by-passed)
  • the difficulty of maintaining confidentiality
  • the benefits of an independent helpline
  • how an employee can make an external disclosure


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