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Step-by-Step Guide to Implementing a Whistleblower System

Our detailed checklist will guide you through the essential steps for successfully implementing a whistleblower system in your company. Create transparency, promote ethics, and make a strong statement for a trustworthy corporate culture.

Does the new directive apply to me?

  • Companies with 250 or more employees: Implementation should have been completed by July 2, 2023.
  • Companies with 50 or more employees: Measures must be implemented by December 17, 2023.
  • For companies with fewer than 50 employees: Special regulations apply, which can vary depending on the industry, such as real estate, insurance, and financial services.

ToDos for implementation

You need to consider the following steps when implementing the directive:

Set up a reporting channel

Provide your employees with the means to submit reports confidentially and securely. Implement automated processes to ensure effective collection and handling of reports. Reports should be documented as anonymous but traceable.

Establish internal expertise

Ensure that your company has the necessary knowledge and resources to establish an internal reporting channel. If necessary, consider involving external experts to ensure efficient setup and operation of the reporting channel.

Define responsibilities

Clearly define which internal employees are responsible for compliance with the Whistleblower Protection Act. If needed, consider outsourcing these tasks to specialized service providers to meet legal requirements.

Hire external support

Engage an experienced service provider to facilitate compliance with the Whistleblower Protection Act. Ensure that they have comprehensive knowledge of whistleblower protection and legal requirements. Clarify the responsibilities of the service provider and establish clear communication channels.

A written contract is crucial and should cover the scope of services, confidentiality, data protection, liability, duration, compensation, and other details to protect your interests.

Establish processes

Limit the number of individuals who have access to incoming reports to prevent possible retaliation. Develop internal guidelines for the secure and confidential handling of reports. Pre-establish escalation paths and clear investigation procedures to ensure an appropriate response to reports.

Inform employees

Raise awareness among your employees about whistleblowing and encourage them to report violations. Involve employee representatives in the selection of the reporting channel to include their perspective. Educate your staff about the Whistleblower Protection Act and the use of the reporting channel, which should be easily accessible and up-to-date. Ensure that all employees know how to report misconduct safely and confidentially, including anonymous reporting. Provide clear instructions on submitting reports.

Appoint ombudspersons

Consider appointing an ombudsperson as an independent point of contact for whistleblowers. This neutral entity adds additional confidentiality and security. Ensure that the ombudsperson has the necessary authority and resources to investigate reports. Clearly inform your employees about this option. This contributes to the effective investigation of reports and ensures appropriate actions are taken.

And get started

Once all necessary preparations have been made, you have done everything required and can now proceed without restrictions.