Whistleblowing in practice: five takeaways

Szymon Szurgacz

It is already six months since the effective date of the whistleblower protection law, yet many firms have still not managed to implement it in practice. Lack of appropriate tools or qualified personnel, interpretive doubts and low confidence in the reporting system among employees are the most frequent issues.

This shows that putting procedures in place is of itself not enough and that, crucially, such procedures must actually work in the organisation. Businesses should focus not just on regulatory compliance but also on building a culture of openness and safety for whistleblowers.

Things worth paying attention to

✔ Check if your organisation has established the right headcount determination reference date – this is 1 January 2025 (with headcount to be reverified every six months, meaning the next headcount determination reference date, 1 July 2025, is coming soon).
✔ Take care to develop effective reporting channels – allowing reports to be made at least orally or in writing and on a confidential basis.
✔ Appoint responsible persons or teams and train them in report processing.
✔ Clearly communicate whistleblower protection rules and build confidence in the system – employees’ reservations are a real barrier.
✔ Monitor and update your policies/procedures – these are not just documents to be put away on the shelf but a living response mechanism.

Implementing an effective whistleblowing scheme is a process but not having one may cost you more than a whistleblowing report itself. Today, employee confidence and the organisation’s self-regulatory capabilities are crucial risk management assets.

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