Whistleblowing Best Practices and Whistleblowing Arrangements Part 3

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Continuous Improvement

You should review your arrangements on a quarterly basis to ensure that the arrangements can be improved. Things to consider include;

Are you receiving more or less reports than you might expect? If the reporting rate is decreasing you might consider refreshing your service promotion efforts to remind employees of the availability of the service.

Does your organisation have a specific issue which could warrant a targeted campaign?

Are cases being resolved in a timely and effective manner?

Are those reporting their concerns suffering from detrimental treatment as a result?

Have you received any feedback from stakeholders, including those raising concerns on how to make the arrangements more effective?

Have you changed your control environment to mitigate risks surfaced through your arrangements?

In the Context of your Organisation
Your whistleblowing arrangements will vary depending on organisational size and complexity.
Smaller organisations may not have appropriately trained independent resources available to manage cases entirely in-house.

Larger organisations may have appropriate resources, either distributed amongst different divisions or managed centrally, to complete the process entirely in-house, but may look to third parties for flexible resourcing or specialist skills and experience.

We find that Promotion, Assessment and Outcomes are best delivered by the organisation, with assistance and guidance from a third party.

Intake and Investigation activity benefit from the independence and specialist expertise provided by third parties, supported by the organisation.

Specialist 3rd parties can be useful at every stage of the process, however independent organisations add the most value in the Intake and Investigation phases due to their ability to protect Whistleblowers and act free from conflicts of interest.


Mechanisms for reporting unacceptable behaviour are not new and many organisations have well-resourced and highly effective arrangements. It is vitally important that businesses share their arrangements to establish and promote best practice in this area.

Increasingly these organisations which embrace misconduct reporting are differentiating themselves, not only through their commitment to responsible business practices, but through their results as they start to shed the direct and indirect drags on their performance.

Conversely, placating, ignoring, failing to protect or retaliating against whistleblowers will bring increasingly serious consequences to organisations and senior leaders.

Being able to demonstrate effective and efficient whistleblowing arrangements will stand any organisation in good stead should they fall victim to serious misconduct. This may be through early detection and resolution or the ability to demonstrate that the organisation did everything in its power to detect and resolve misconduct.

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