Here’s What You Need in Your Whistleblower Policy (and Why)
How to create a whistleblower policy that protects employees and prevents misconduct.
Table of Contents
Purpose and Scope
Like every workplace policy, start by stating the purpose, or why you’ve put this policy in place. What objectives do you hope to achieve with your whistleblower policy? Be specific, but tie into the overarching goal: committing to an ethical workplace. For example:
The purpose of this whistleblower policy is to protect the integrity of [Company Name] and its employees. This policy is designed to inform employees of the ways they can report concerns and suspicions of wrongdoing. Please read this policy in conjunction with [Company Name]’s other internal documents, including:
- code of conduct
- fraud policy
- harassment policy
Without a clear purpose, employees might look at this policy as just more rules. Let them know that it’s in place for their safety, and that it’s in their best interest to follow the reporting procedures you outline.
Next, outline the scope of your whistleblower policy, or who it applies to. Policies and procedures often differ in what types of employees and business partners they apply to and when in the business relationship they apply, so make this part clear. For example:
This whistleblower policy should be applied by and to the actions of every employee, intern, contractor, consultant and other stakeholder. This document is reviewed annually by a committee of employees, but is subject to change more often if an incident occurs or procedures have been updated.
Without a clear scope, your whistleblower hotline might not be used to its potential. Employees might not report on someone because they don’t think the person is covered by the policy (e.g. contractors, consultants or interns). As a result, an issue could escalate from a one-time problem (like petty theft or an inappropriate comment) to a big disaster (like a major fraud scheme or sexual assault).
What to Report
Give specific examples of the types of behavior employees should “blow the whistle” on. This section is like the scope, but instead of who the policy applies to, it’s the what. For example:
Reportable offenses under this policy include:
- Harassment and discrimination: discrimination in hiring/promoting decisions, bullying, sexual/physical/psychological harassment as defined in [Company Name]’s harassment policy
- Fraudulent activity: theft, benefits fraud, bribery, misuse of funds, misrepresentation of funds, other fraud as defined in [Company Name]’s fraud policy
- Ethics concerns: nepotism, conflict of interest, corruption, retaliation or retribution against parties who report concerns, abuse of power
- Compliance lapses: breaches of relevant laws, regulations and reporting requirements [Company Name] is subject to
- Other misconduct: endangering other parties’ health and safety, violation of [Company Name]’s policies, concealment of violation of this or another policy on behalf of another party
All reports received through the aforementioned channels will be treated as serious concerns. [Company Name] trusts that reporters submit their concerns in good faith. Reports that are found in violation of this assumption could result in disciplinary action up to and including termination of employment or dissolution of the business relationship (for contractors and partners).
If employees don’t know what types of behavior they should report, your whistleblower program won’t do much good. Unaddressed issues could put employees in danger and cost you money and time later. Plus, you won’t know where to focus your preventive efforts.
RELATED: Should You Allow Anonymous Reporting on Your Whistleblower Hotline?
A weak policy leaves employees and your company vulnerable.
Prevent disasters by establishing a culture of ethics
Employees who know how to report their concerns (and don’t fear retaliation) are more likely to report. That way, you can address problems before they escalate. Communicate how and why whistleblowing is important in your company whistleblower policy. Use our free template to get started.
How to Report
This is the most important section of your whistleblower policy. Employees need to know how and where they can submit reports of wrongdoing. Describe how to use all your channels in detail so whistleblowers know their options. For example:
[Company Name]’s whistleblower hotline is accessible [list hours and days here]. To access this service, call XXX-XXX-XXXX. [If you are a worldwide company, include the hotline numbers and hours for each country, if applicable]
Online Complaint Form
To submit a report online, visit our web-based hotline at [URL]. Fill in the nature of your complaint, details and your contact information, or select the “submit anonymously” box to make an anonymous report. This channel is open 24 hours a day, 7 days a week and monitored actively during regular business hours.
[Company Name] Ombudsman
Should you wish to submit a report in person, please visit the [Company Name] ombudsman’s office. [Include name(s) of staff and office location/numbers] There you can make a complaint in person or by completing a reporting form. This office is open [list hours here].
Reporting mechanisms that are hard to find or use put your company and employees in danger. Employees simply won’t report when they should, leaving you unaware of current and potential issues that need attention.
Hidden or hard-to-use channels can also make it seem like you don’t want whisteblowers to report. Show you’re committed to an ethical workplace by offering multiple reporting options with good user experience.
Finally, emphasize your company’s promise to never retaliate against a whistleblower. For example:
Retaliation of any kind against a reporter is strictly prohibited. If any party is found to harass, discriminate against or otherwise retaliate against a person who has submitted a complaint, they will be subject to disciplinary action up to and including termination of employment or dissolution of the business relationship, and/or legal action.
This statement shows that you’re committed to maintaining an ethical work environment. Employees will see that you care about them and that you won’t put profit or your company’s reputation ahead of their well-being.
In turn, they’ll be more willing to report wrongdoing, which will help you nip problems in the bud and boost your prevention efforts.
RELATED: A Practical Guide to Whistleblower Protections in 2020
When you create a strong whistleblower policy for your workplace, you should see incidents and issues decrease. Employees are invaluable sources of information for detecting problems early and identifying hot spots you can focus on for prevention.
What good will a whistleblower hotline do if nobody uses it?
Whistleblower hotlines tip employers off to issues, but if employees don’t know how to use them, the workplace is at risk. Download and hang this free hotline poster in common areas to raise awareness and encourage a culture of ethics at your company.