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Developing A Whistleblowing Policy

  • Datalaw Admin
  • Mar 8, 2019
  • 0 comment(s)


Whistleblowing means sharing of information which relates to supposed wrongdoing. A whistleblower is essentially a person who could be an employee of an organization or government agency who provides information to the public or higher authorities as regards wrongdoings (illegal activities, fraud, breach of the agreement, corruption, and etcetera) happening in such organization. They are usually categorized into external and internal whistleblowers, the latter reports any issue of wrongdoing to agencies other than the organization in question while the former report such issues to the authorities of the organization.


To secure the job and life, in some instances of the whistleblower, companies and government agencies do have a policy and procedure for reporting such cases. The policies are usually aimed at encouraging the report of wrongdoing for investigation, handling such reports with a great sense of confidentiality.


The policy normally applies to every individual that carries out work in the organization (public/private). The list includes; all employees, partners of the company, contractors, consultants, staffs from agencies. Genuine interest in any act of wrongdoing that should be reported under this policy;

  •         Serious misconduct
  •          Violation of codes of conduct as stated for all professionals in such organization or company
  •          Illegal and unethical conducts
  •          Violation of legal requirements
  •          Breach of the company’s independence policy
  •          Breach of audit regulations.

The policy should encourage internal whistleblowing, it should be safe and easily accessible. It should also encourage the independent investigation of concerns and thorough follow-up mechanism. It should also provide ease of external reporting to bodies concerned or media. The whistleblower should also be recognized as an important and active stakeholder that must be informed about the processes and outcomes of the investigation. A reward system should also be adopted to encourage whistleblowing when the policy is to be made.

Procedure for whistleblowing (internal)

·         Get the evidence of wrongdoing

·         Gathering of information

·         Report to your immediate superior about it.

·         If you feel uncomfortable telling your superior for whatever reason, you should report to your head of the department.

·         However, if you could not for any reason, you should report to the management or the HR as the case may be. You should, however, know that it is not your duty to carry out an investigation.

Procedure for whistleblowing (external)

·         The procedure for internal whistleblowing applies for external whistleblowing, In extreme cases, wrongdoings are reported to external bodies or persons such as lawyers, government agencies, media, watchdogs etc. monetary rewards may be offered to encourage external whistleblowing.


Following the allegation of wrongdoing;

  •         The matter should be investigated by the management, disciplinary committee or internal audit as the case may apply
  •          Reported to the relevant agency
  •          Referred to the police, external auditing
  •          Subject to an independent inquiry.

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