Culture and Protocol: How to Create a Pro-Whistleblowing Environment

With an editorial in the Globe and Mail, it’s great to see that whistleblowing is finally getting the attention it deserves.

It’s stunning to think about how the course of history could have changed if insiders had the courage or ability to report wrongdoing. If internal whistleblowing is impossible or not culturally encouraged, organizations put themselves, their employees, and society at risk.

As with many other issues, my first advice to companies about whistleblowing begins with culture. If your organization’s culture is one of fear where employees can expect personal or professional retribution from whistleblowing, then no one is going to ever come forward – regardless of what official policies you may have in place.

Important Steps to Create a Whistleblowing Protocol

These steps should be taken first to fix company culture, and then you can work on official whistleblowing protocol, which should look something like this:

  • The reporting mechanism should use an independent, external 3rd party. The 3rd party should communicate the wrongdoing to 2 different people in the organization.
  • The policy should state that information provided must be clear, truthful, and in good faith.
  • The policy should require information detailed enough to deter false, frivolous, or bad faith claims. Specifically: who is involved, the action/non-action of concern, where and when the wrongdoing occurred, witnesses to the behaviour, and why the whistleblower thinks it’s wrong.
  • Confidentiality should be guaranteed. No attempt to discover the whistleblower should be made. The policy should encourage the whistleblower to reveal their identity to the investigation (as total anonymity could comprise its effectiveness), but no one outside the investigation should have a mechanism to uncover the whistleblower’s identity.
  • A strict non-retaliation policy must be stated, adhered to, and enforced.
  • Every reported case should be investigated.
  • Whistleblowers should receive an update on the investigation, otherwise the whistleblower may take their concerns to the media or another third party – potentially damaging the organization.
  • In reviewing reports, the analysis should proceed on the assumption that the report was made in good faith, unless there is clear evidence to rebut that assumption.
  • Make it clear that whistleblowing is to be expected as a matter of duty when an employee witnesses wrongdoing.
  • Publicize the program. One company took pride that there had never been a report through its program, only to learn that few employees knew it existed.
  • Senior management support for whistleblowing must be clear and unequivocal, seen both in word and deed.

Advice for Employees

Finally, some advice to employees. If your organization does not have a system in place similar to the one described above, or you do not trust assurances of confidentiality/non-retaliation, then I would advise making a report to the organization’s external auditor. When you do this, seek a written assurance that confidentiality is protected.

Regardless of how you report, don’t embellish, assess, or be judgmental. Don’t become the investigator. Simply state what you believe is wrong and why – if you reach beyond that, you risk being seen as a witch hunter. 


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