Purpose and Scope
This policy outlines how anyone working for [Organisation Name], including employees, workers, agency staff, contractors, and volunteers, can report suspected internal wrongdoing.
Do not use this policy for standard workplace complaints:
- Use the Grievance Policy or Bullying and Harassment Policy for personal employment terms or treatment.
- Use the standard Complaint Handling Procedure for customer complaints.
If a report involves both whistleblowing and a personal grievance, [Organisation Name] will split the issues and process each under its respective policy.
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.
Policy Statement
[Organisation Name] acts on internal wrongdoing quickly. We support anyone who raises a genuine concern under this policy and protect them from unfair treatment, whether or not the investigation substantiates the report.
Reportable Concerns
This policy applies to disclosures concerning:
- Criminal activity, such as theft, fraud, or bribery.
- Failure to comply with legal or regulatory obligations.
- Health and safety risks to staff, customers, or the public.
- Environmental damage.
- Miscarriages of justice.
- Misuse of personal data or serious confidentiality breaches.
- Deliberate concealment of any of these issues.
Procedure for Raising a Concern
- Submit your report to the [Designated Whistleblowing Officer]. If the report involves this individual, send it to the [Alternative Designated Senior Role].
- Provide your report in writing or verbally. We will document verbal reports in writing and confirm the text with you.
- Detail all known facts, including dates, locations, names, and supporting documents. You do not need to investigate or prove the claims yourself.
- State whether you are reporting openly, confidentially, or anonymously. We accept and review anonymous reports, but staying anonymous may limit how deeply we can investigate, how we update you, or how directly we can protect you.
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Handling and Investigation Procedure
- Acknowledge receipt of the concern within [Number] working days.
- Assess the issue to decide the next step. Actions may include an internal investigation, escalation to the [Board/Executive Committee], or referral to external regulators or authorities.
- Assign an independent investigator with no prior connection to the issue to gather evidence confidentially and proportionately.
- Send progress updates to the person who reported the concern, including estimated timelines and the final outcome where confidentiality allows.
- Log the concern, investigation steps, and findings in [Confidential Register Location]. Take corrective action to fix any identified procedural or operational gaps.
Protection and Confidentiality
- Anyone raising a genuine concern under this policy will not face dismissal, demotion, victimisation, cut hours, or exclusion.
- Retaliating against someone who reports a concern is a disciplinary offence and may amount to gross misconduct.
- We keep the reporter’s identity confidential as far as possible.
- We handle malicious or knowingly false reports under the Disciplinary Procedure.
External Disclosures
- You retain the legal right to make a protected disclosure to a relevant external prescribed body or regulator.
- Nothing in this policy, employment contracts, or settlement agreements stops you from making a protected disclosure to an external regulatory authority.
Records and Review
- The [Designated Role] manages the whistleblowing register, restricts access to it, and retains records per organizational data retention schedules.
- The [Board/Executive Committee] reviews anonymised reports on a [Frequency] basis to spot systemic issues and trends.
- We review this policy [Frequency] and after completing any whistleblowing investigation.
- Policy Owner: [Role].
- Next Review Date: [Date].
FAQs on a whistleblowing policy
What is a whistleblowing policy?
A whistleblowing policy outlines how anyone working for your organisation, including employees, workers, agency staff, contractors, and volunteers, can report suspected internal wrongdoing.
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 whistleblowing policy include?
This template covers reportable concerns, procedure for raising a concern, handling and investigation procedure and protection and confidentiality.
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 whistleblowing 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.