Global Anti-Bribery Guidance

Best practice for companies in the UK and overseas

16. Whistleblowing

Best Practice Guidelines

Open culture: Build a culture of trust so that employees feel able to seek guidance or discuss issues with their managers or the relevant support functions and are confident to use speak up channels if they feel this is necessary.
Consider an external provider: Decide whether greater confidence will be provided to employees and third parties if a speak up channel is provided internally or managed by an independent provider.
Human resources is a key player: Involve the human resources function in all aspects of development, design, monitoring and improvement of the advice and speak up channels.
Provide a range of channels: Create a range of ways for employees to seek guidance. In addition to a hotline, companies should encourage discussions with line managers, or encourage management to have an open door policy. Opportunities to meet with compliance officers, personnel managers or relevant networks of employees should also be created.
Communicate: Explain how to use the speak up channel, what feedback will be received, how confidentiality is safeguarded, and how the employee will be protected. This can be done through the training programme, for example.
Make the advice channels resources of choice: Positioning and designing the advice line as a resource can increase its use and will help avoid employee error, misjudgement or improper conduct.
Promptness: Deal with matters raised promptly. Check case closure times as delays can weaken employees' trust in the process and the company’s commitment to integrity. Delays may also have legal consequences.
Complete the process: Ensure that every case follows the relevant process through to conclusion and that the employee is thanked for their commitment to upholding standards in using the channel. If possible employees should be asked to comment on their satisfaction with the process, although it should be noted that not every case will reach an outcome sought by an employee.
Act on concerns: Inform senior management promptly about speak up cases where they are well founded and of high significance.
Proper treatment: Ensure that those who speak up are not harassed or penalised, but recognised or rewarded for their efforts.
Independent review: Review the effectiveness of the channels whilst ensuring users’ identities are protected.
Analyse: Monitor and analyse the use of advice and speak up channels as they can provide early warning signs, such as that the bribery programme may need attention. Capture data from all channels used to seek advice including discussions with management, compliance, HR and other functions.
Ensure review by leadership: Report critical issues promptly to senior management and provide regular reports to senior management and the board on the use of the channels including any implications.
Report publicly: Let stakeholders know that your company operates with an open integrity culture, and that the company is trusted by, and trusts, employees. Reporting should detail how employees and others are encouraged to seek advice, raise concerns or blow the whistle. Report regularly and openly both internally and externally on the use, adequacy and effectiveness of the advice and speak up channels including information on the procedures, topics raised, handling and outcomes.