Blowing the Whistle – Making a Whistle Blower Policy Work

The United Kingdom National Audit Office recently released a very interesting review of the effectiveness (or otherwise) of whistle blowing programs within the United Kingdom civil service.

As the report contextually notes:

Whistle blowing is important to protect and reassure the workforce, and to maintain a healthy working culture and an efficient organisation.

The scope of the work provides a neat articulation of the strategic issues that any organisation – government or private – need to consider:

We evaluated the whistleblowing policies of 39 government bodies and highlighted good practice.

However, having a policy in place is only the first step. For whistle blowing to work, the culture of an organisation needs to support and enable the systems, structures and behaviours through which it can work effectively. In this report we have examined:

– systems to support whistle blowing arrangements, including the clarity of governance arrangements and the availability of intelligence;

– structures that are in place to enable whistle blowing, particularly through complex delivery chains; and

– behaviours to support and enable a positive environment in which whistle blowing is accepted.

The report noted that organisations should ensure whistle blowing arrangements are clear and are communicated, by:

  • sharing their own policies and procedures with their delivery partners so that these organisations know of, and are attuned to, the standards of conduct of public business that taxpayers expect;
  • including details of any central hotlines or reporting sources, so all employees are aware of them; and
  • reviewing their delivery partners’ arrangements so they are coherent

Organisations should make sure that existing governance mechanisms are being exploited to optimal effect in relation to whistleblowing, by defining and clarifying the relative responsibilities of internal audit, audit committees and human resources.

Sponsor organisations should encourage intelligence held by delivery partners to be shared with them, so they are able to exercise efficient oversight to:

  • identify trends, possible system failures or specific issues;
  • collect, analyse, and disseminate lessons learned and common risks; and
  • target ares of risk for which there are weaknesses in controls or where staff need training.

Organisations should promote policies and procedures to raise the awareness of staff, and keep them up to date with current thinking and best practice. Organisations should:

  • create an open and accountable culture with those at the top taking a lead on the whistle blowing policy to show that concerns will be taken seriously – nominating a senior officer to promote the arrangements will contribute to this aim;
  • ensure their policies cover the key factors that should be included in a whistle blowing policy;
  • review their arrangements periodically; and
  • introduce appropriate training at all levels on the whistle blowing arrangements and legislation.

To reassure the workforce, organisations should publish, internally and at a high level, the number and type of cases they have received, and also the results to:

  • enable employees to see the results of cases investigated; and
  • promote a positive message about whistle blowing.

When publishing information, protocols should be in place to ensure there is no risk that a whistleblower’s identity will be revealed.

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