Whistleblowing policy

A whistleblowing policy tells people how to raise a concern about wrongdoing, what the organisation will do with it, and how they are protected for having raised it. The legal framework is the Public Interest Disclosure Act 1998, which gives workers who make a protected disclosure the right not to be dismissed or subjected to a detriment for it.

Those protections cannot be contracted out of. A confidentiality clause, a settlement agreement or a contract of employment is void so far as it tries to stop a worker making a protected disclosure. That is worth checking against your existing contracts and settlement wording, because standard confidentiality drafting frequently goes further than it is allowed to.

Name someone, or it will not be used

The policy asks you to name a whistleblowing officer and a senior alternative, both in the reporting clause and in the table. A policy that names nobody, or names a role that has been vacant for a year, does not get used. The alternative matters as much as the primary contact, because the concern may be about the primary contact.

Do not require internal reporting first

Encourage people to raise concerns internally, but never say they must. A worker can go straight to a prescribed regulator and remain protected, and a policy that requires internal reporting first is likely to be held against the employer rather than the worker.

What the policy covers

Purpose and commitment. Who is covered, which extends well beyond employees to workers, agency workers, contractors and their staff, and former staff in relation to something they learned while working for you. What should be reported, with a worked list running from fraud and bribery through health and safety, environmental damage and data protection failures to the deliberate concealment of any of them. What the law protects and how a disclosure qualifies. How to raise a concern, what happens next, confidentiality and anonymity, protection from victimisation, and what to do if the concern is about a director. Records and review.

The wording reflects the Employment Rights Act 2025, including sexual harassment as an express category of protected disclosure from 6 April 2026.

Keep the log

Record every concern raised, what was done about it and the outcome, and review the log for patterns. Take advice early where a concern involves a director, a possible criminal offence, a regulator, or any decision to discipline or dismiss someone who has blown the whistle.