Use this template to create a whistleblowing policy.

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Whistleblowing Policy

[Company Name]

Policy Owner: [Senior Manager/Director] Last Reviewed: [Date] Next Review: [Date]

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1. Introduction

1.1 Policy Statement

[Company Name] is committed to the highest standards of openness, honesty and accountability. We encourage employees to report concerns about wrongdoing at the earliest opportunity.

This policy provides a framework for employees to raise genuine concerns internally without fear of reprisal.

1.2 Scope

This policy applies to:

• All employees
• Officers and directors
• Agency workers and contractors
• Suppliers and those providing services

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2. What is Whistleblowing?

Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include:

Type of Concern	Examples
Criminal offences	Fraud, theft, bribery, corruption
Failure to comply with legal obligations	Regulatory breaches, health and safety failures
Miscarriages of justice	Unfair treatment in disciplinary matters
Dangers to health and safety	Unsafe working conditions
Damage to the environment	Illegal dumping, pollution
Deliberate concealment	Cover-up of any of the above

2.1 What is Not Whistleblowing

This policy is not for:

• Personal grievances (use Grievance Procedure)
• Complaints about your own employment terms
• Matters that don't involve suspected wrongdoing

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3. Safeguards

3.1 Protection from Retaliation

We will not tolerate any harassment, victimisation, or disadvantage of anyone who raises a genuine concern in good faith.

Anyone who victimises a whistleblower will be subject to disciplinary action.

If you believe you are being victimised for raising a concern, report this immediately to [Senior Manager/HR Director].

3.2 Confidentiality

We will treat all concerns confidentially where possible. However:

• We may need to disclose your identity if required by law
• Investigation may reveal your identity as a practical matter
• Anonymous concerns are harder to investigate

We encourage you to put your name to your concern whenever possible.

3.3 Anonymous Concerns

Anonymous concerns will be considered, but:

• They are more difficult to investigate
• We cannot provide feedback
• Credibility may be harder to establish

Consider whether you can raise the concern openly with confidentiality protection.

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4. How to Raise a Concern

4.1 Internal Reporting

You may raise concerns with:

Contact	When to Use
Your line manager	First option for most concerns
[Senior Manager name]	If concern involves your manager
[HR Director name]	Alternative contact
[Non-executive director name]	If concern involves senior management

You can raise a concern:

• In person
• In writing
• By email to [dedicated email address]
• By phone to [number]

4.2 What to Include

When raising a concern, please include:

• The background and history
• Names, dates, places where known
• The reason for your concern
• Any evidence or documentation

You are not expected to prove wrongdoing - genuine concerns will be investigated.

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5. How We Will Respond

5.1 Acknowledgement

We will:

• Acknowledge your concern within [5] working days
• Indicate how we propose to deal with it
• Give an estimate of time for a full response

5.2 Investigation

We will:

• Conduct a proportionate investigation
• Appoint an appropriate investigator
• Keep you informed of progress where appropriate
• Respect confidentiality

5.3 Outcome

After investigation, you will be told:

• Whether your concern was substantiated
• What action has been taken (within confidentiality limits)
• Whether the matter has been referred externally

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6. External Reporting

6.1 When to Report Externally

This policy encourages internal reporting first. However, you may report externally where:

• The matter is exceptionally serious
• You believe you would be victimised for internal reporting
• You believe evidence would be concealed or destroyed
• You have raised the matter internally and it has not been addressed

6.2 Prescribed Persons

You may report to relevant regulators and prescribed persons, including:

Regulator	Type of Concern
Health and Safety Executive	Health and safety matters
Environment Agency	Environmental matters
Financial Conduct Authority	Financial services matters
HMRC	Tax fraud
National Crime Agency	Serious crime
[Others relevant to your sector]

A full list of prescribed persons is available at gov.uk.

6.3 Legal Advice

You may wish to seek legal advice before making an external disclosure to ensure your disclosure is protected.

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7. Responsibilities

7.1 All Employees

• Report concerns about wrongdoing
• Cooperate with investigations
• Maintain confidentiality about concerns raised

7.2 Managers

• Take all concerns seriously
• Escalate concerns appropriately
• Protect whistleblowers from retaliation
• Maintain confidentiality

7.3 Senior Management

• Ensure this policy is implemented
• Foster a culture where concerns can be raised
• Ensure concerns are properly investigated
• Take action on findings

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8. Malicious Allegations

While we protect genuine concerns raised in good faith, malicious allegations made with intent to cause harm or without reasonable belief in their truth will be treated as a serious disciplinary matter.

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9. Record Keeping

We will maintain confidential records of:

• Concerns raised
• How they were investigated
• Outcomes and actions taken

These records will be kept securely and retained for [6] years.

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10. Training

All employees will be made aware of this policy.

Managers will receive training on handling whistleblowing concerns.

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11. Review

This policy will be reviewed annually.

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Key Contacts

Role	Name	Contact
Whistleblowing Lead	[Name]	[Email/Phone]
Alternative Contact	[Name]	[Email/Phone]
External Advice	Protect (charity)	020 3117 2520

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Document Control

Version	Date	Author	Changes
1.0	[Date]	[Name]	Initial version