A whistleblower policy establishes a process that allows the board, employees, volunteers and other interested parties the ability to report in good faith any suspicions they may have regarding illegal, unethical or inappropriate actions.
When developing a Whistleblower Policy, the following should be considered:
- The policy should include protection for all those involved with the organisation, including directors, employees, volunteers and other with an interest in the organisation (eg. members).
- The policy should clearly set out what should be reported such as fraud, workplace safety issues, misconduct, breaches of policies, any activity that is illegal, abuse of authority etc.
- The policy should clearly set out to whom and how someone should report suspicions. The person to whom reports are made should carefully be chosen. For example, it is suggested that it is not someone who has access to the organisation’s funds such as the financial controller as these are people who may be the subject of the reports. It is also appropriate to have a secondary reporting person for when the initial person in on leave or if the report is being made about that person. Also these two people need appropriate training on their responsibilities.
- The option of using an external whistleblowing service should also be considered rather than utilizing an internal person. These services are readily available and should be investigated. The provider of the services will take reports and either provide those reports to an appropriate person internally to investigate or assist the organisation with the investigation.
- It is recommended that a “line manager” is not an appropriate reporting person. The reasons for this are that it may be the line manager who the report is being made about and therefore it could make it difficult for the whistleblower to make a report. It requires training all line managers with their responsibilities as a receiver of reports rather than one or two people who deal with the issues on a regular basis.
- When a person reports their suspicions they must be able to do so without fear of retaliation. However, it must also be clearly set out that a person will be dealt with if the report is made maliciously.
- People should be able to make reports anonymously if they chose. However, people should understand that by making a report anonymously they may slow down the investigation. For example, the investigator cannot check with the person for additional information.
- To reduce the possibility of anonymous reports, the policy should clearly promise confidentiality to the extent it is possible. For example, it may be necessary to advise law enforcement of the name of the person who made the report.