1. Purpose and Scope
This policy outlines how personnel report suspected wrongdoing and details the protections given to whistleblowers.
This policy applies to all [Organisation Name] personnel, including employees, officers, contractors, and temporary staff. It covers reports regarding the organisation, its staff, and its representatives.
This policy is not an employment contract. It does not alter employment status or restrict anyone from reporting suspected legal violations directly to external government authorities at any time.
Working through related paperwork at the same time? See also our Anti-Bribery & Corruption Policy Template, Anti-Bribery & FCPA Policy Template and US Anti-Harassment Policy Template.
2. Reportable Conduct
Report any activity you reasonably believe involves unlawful conduct, serious safety hazards, or significant policy breaches. Reportable matters include, but are not limited to:
- Health and safety hazards, unreported injuries, or pressure to work unsafely.
- Theft, fraud, or falsification of records, timesheets, or financial statements.
- Bribery, kickbacks, or undisclosed conflicts of interest.
- Statutory or regulatory violations.
- Retaliation against anyone for reporting a concern or participating in an investigation under this policy.
- Harassment or discrimination (reports received under this policy will be routed to [Designated HR Department/Role] under the relevant policy).
3. Reporting Channels
Submit reports through any of these channels:
- Direct Management: Speak with your direct supervisor or manager for issues suitable for local resolution.
- Human Resources / Compliance: Contact [Designated Role / HR Contact] by [Phone / Email / In Person] if local resolution is inappropriate or involves your manager.
- Reporting Line: Use [Designated Reporting Line / Web Form], which accepts [Anonymous / Identified] submissions. We investigate anonymous reports to the extent the details allow.
- Governance / Oversight: Contact [Senior Leader / Audit Committee] for concerns involving executive management or financial reporting irregularities.
- External Authorities: Report directly to relevant statutory or regulatory government agencies at any time, independent of internal reporting processes.
4. Anti-Retaliation Protections
- Retaliation Prohibited: Retaliating against anyone for making a good-faith report or participating in an investigation is prohibited. Violations carry disciplinary consequences up to termination of employment.
- Defined Actions: Retaliation includes any adverse action tied to a report, such as termination, demotion, formal discipline, reduced hours, denied promotions or training, exclusion, threats, or harassment.
- Good-Faith Reporting: Protections apply to honest reports, even if an investigation cannot substantiate the concern. Good-faith reports carry no penalty.
- Improper Use: Knowingly filing false or malicious reports is misconduct and will be handled under [Disciplinary Policy Name].
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5. Investigation and Handling Procedure
- Acknowledge receipt within [Timeframe] if the reporter’s identity is known, and provide the name of the assigned intake officer.
- Assign an impartial investigator through [Designated Role]. The investigator must have no direct interest in the outcome, cannot be named in the report, and must not report to anyone involved in the matter.
- Conduct the investigation by reviewing records, interviewing relevant personnel, and documenting findings. Escalate serious matters, such as legal violations, financial reporting concerns, or senior management involvement, immediately to [Senior Leader / Legal Counsel / Audit Committee].
- Notify the reporter when the investigation closes, sharing resolution details where confidentiality permits.
- Log all findings, corrective actions, and completion dates in [Designated System / Location].
6. Confidentiality
- We keep reports and investigation details confidential, sharing information strictly on a need-to-know basis with individuals directly involved in the investigation or remediation process.
- If a thorough investigation requires revealing specific details or identities, we cannot guarantee absolute anonymity. However, anti-retaliation protections apply regardless of disclosure.
7. Records, Roles, and Policy Review
- Record Retention: Store reports, investigation files, and outcome summaries in [Designated System / Location]. Restrict access to [Authorized Roles] and retain files for [Retention Period].
- Trend Monitoring: [Designated Role] reviews the report log [Frequency] to identify recurring issues, location trends, or reporting channel usage.
- Review Cycle: Review this policy [Frequency / Annually], after any substantiated retaliation incident, or following statutory changes.
- Policy Owner: [Designated Role].
- Next Review Date: [Date].
FAQs on a whistleblower policy
What is a whistleblower policy?
A whistleblower policy outlines how personnel report suspected wrongdoing and details the protections given to whistleblowers.
Having it written down means the same rules apply to everyone, so managers are not making judgement calls case by case under pressure.
What does a whistleblower policy include?
This template covers reportable conduct, reporting channels, anti-retaliation protections and investigation and handling procedure.
Every section is written to be filled in. The bracketed placeholders mark the decisions that are yours to make, such as timescales, approval owners and retention periods.
How to implement a whistleblower policy with Whale
Copy this template into Whale and work through the bracketed placeholders so it reflects how your organisation actually operates.
Assign it to the teams it applies to so it sits where people work rather than in a shared drive, and set a review date so it gets revisited on schedule instead of quietly going out of date.
Use our templates to fast-track your documentation
Customize this template and 100s of others for free in Whale, the fastest way to get your team aligned.