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Use this model whistleblowing policy to detail the framework in which employees and others who have serious concerns about any aspect of your business can voice those concerns.
1 Overview
1.1 All organisations face the risk of things going wrong or of unknowingly harbouring malpractice.
1.2 By promoting a culture of openness within [Company], employees are encouraged to raise issues which are of concern at work. By knowing about malpractice at an early stage, steps can be taken to safeguard the interests of all staff and prevent fraud and corruption before it happens.
2 Scope
2.1 This policy applies to all persons working for us or on our behalf, including employees at all levels whether permanent or temporary, directors, agency workers, interns, and contractors.
2.2 This policy should not be used in relation to employee grievances concerning individual terms and conditions of employment or other aspects of the working relationship which are handled under the Company Grievance Policy.
3 General Principles
3.1 Policy statement
3.1.1 All employees have the right to be able to raise a concern about working practices and other areas of concern in the public interest and receive feedback on actions taken.
3.1.2 [Company] will seek to engender an ethical and open culture in which establishes safe routes of communication without reprisal, impartial and effective investigative procedures which respect confidentiality.
3.1.3 The key principles therefore are to:
Provide avenues for employees to raise genuine concerns internally as a matter of course and receive feedback on actions taken
Ensure that matters are dealt with quickly and appropriately and ensure that concerns are taken seriously.
Re-assure employees that they will be protected from reprisals or victimisation for whistleblowing in good faith.
Allow employees to take the matter further if they are dissatisfied with the response.
3.2 What is whistleblowing?
3.2.1 The term "Whistleblowing" is used to describe a formal disclosure of alleged corruption, malpractice or wrongdoing made to the appropriate person in authority.
In the case of [Company] this disclosure might be the reporting
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A whistleblower is a worker (an employee / trainee / agency worker etc.) reports any of the following:
a criminal offence, for example fraud
someone's health and safety is in danger
risk or actual damage to the environment
a miscarriage of justice
the company is breaking the law, for example does not have the right insurance
you believe someone is covering up wrongdoing
This will usually be something they have seen at work - though not always.
The wrongdoing they disclose must be in the public interest. This means it must affect others, for example the general public.
A whistleblower is protected by law - they should not be treated unfairly or lose their job because they 'blew the whistle'.
They can raise their concern at any time about an incident that happened in the past, is happening now, or they believe will happen in the near future.
A confidentiality clause in a settlement agreement is not valid if the worker is a whistleblower.
Public Interest Disclosure Act 1998 (PIDA): This legislation, commonly known as the Whistleblower Protection Act, is the primary law that protects whistleblowers in the UK. It provides legal protection to employees who disclose certain types of information in the public interest, ensuring they are safeguarded from victimization or retaliation.
Employment Rights Act 1996: Part IVA of this Act, inserted by PIDA, sets out specific provisions regarding protected disclosures, the conditions under which whistleblowers are protected, and the rights afforded to them.
Enterprise and Regulatory Reform Act 2013: This Act introduced changes to whistleblowing legislation, including the requirement for disclosures to be made in the public interest and providing employment tribunals with the power to take into account the reasons behind a dismissal when considering a whistleblowing claim.
Financial Services and Markets Act 2000: This legislation includes specific provisions for whistleblowers within the financial services sector, such as the duty of financial firms to have effective internal whistleblowing channels and protections for whistleblowers against detriment or dismissal.
Public Interest Disclosure (Prescribed Persons) Order 2014: This Order designates specific bodies, such as regulatory bodies, as "prescribed persons" to whom whistleblowers can make disclosures if they believe their employer has not addressed the concerns adequately.
Equality Act 2010: This Act ensures that whistleblowers are protected from victimization or discrimination as a result of making a protected disclosure, irrespective of their protected characteristics.
Company Law: The Companies Act 2006 includes provisions related to whistleblowing for certain types of companies. For example, public companies are required to have a whistleblowing policy in place.
Health and Safety at Work Act 1974: This Act includes provisions that protect employees who disclose health and safety concerns in the workplace.
Data Protection Act 2018 (DPA): The DPA protects whistleblowers by regulating the processing of their personal data and ensuring that their confidentiality is maintained during the investigation of their disclosures.
Yes. This template has been designed for organisations of all sizes, including small businesses, charities and growing employers. It follows UK employment law best practice and can be adapted to suit your organisation.
Our templates are developed with UK employment legislation, Acas guidance and HR best practice in mind and are reviewed and updated as relevant requirements change. However, every employment situation is different, so the template should be adapted to the circumstances and checked against the employee's contract and your organisation's procedures before use.
Yes, we highlight the areas of the document that you need to update with your own details, and where you need to make decisions to suit your situation. This saves you time and ensures that you meet best practice.
Yes. Once purchased, you'll be able to download it instantly. Templates are provided in editable format (such as .doc or .xls) so you can customise them easily, and in PDF format for easy sharing.
If you're looking for broader support, we also offer toolkits and library bundles that include the Whistleblowing policy template, along with other HR templates and policies for fully managing your situation. These may be more cost-effective if you need deeper advice.
AI can produce a document quickly, but effective HR documentation needs to be more than well-written words. It needs to reflect relevant UK employment law, HR best practice, practical considerations and the circumstances in which it will be used. These resources have been professionally developed around that wider HR context, drawing on extensive practical experience, rather than simply generating a generic document from a prompt.
Darryl Horn, Chartered HR Director
Darryl is a Chartered HR professional with over 25 years' experience in senior HR and employee relations roles.
He has extensive practical experience of managing ethical processes and founded hrdocbox to provide businesses with practical, professionally developed HR resources grounded in UK employment law and best practice.
"Darryl provides support and advice with excellent judgement, and has a strong understanding of people, policies and UK employment legislation."
"He is someone I trust; consistent, dependable, and committed to doing things properly."
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