Guide from
[insert your firm’s name here]
Tel: [insert telephone number here] Email: [insert email address here] [Insert web address here]
[Insert a line about your business here]
Edit the above information by clicking directly within the grey panel, or by clicking ‘View’ in the main toolbar and selecting
‘Header and Footer’
A guide to
Whistleblowing procedures
A SIMPLE GUIDE TO WHISTLEBLOWING PROCEDURES
This is a basic guide prepared by ACCA UK’s technical advisory service for members and their
clients. Basic guides should not be used as definitive guides, since individual circumstances may
vary. Always get specific advice.
This guide is aimed at small and medium sized UK owner managed businesses.
INTRODUCTION
All organisations are advised to have whistleblowing policies and procedures in place to protect the
organisation and its stakeholders including employees.
If employees do not have a safe confidential avenue they can use to raise their concerns the
business may miss an opportunity to take corrective action, whist the matter is still easily
manageable, with a possible knock on detrimental impact on the reputation of the organisation.
Whilst there is no statutory requirement for organisations to have a whistleblowing policy in place,
the adequacy of a business’s arrangements is one of the factors that will be considered by
tribunals and courts when determining whether wider public disclosure is protected under
legislation. Further, increasingly regulators and courts are looking at an organisation’s
1
whistleblowing and other risk management arrangements when considering offences such as
financial misconduct or corporate manslaughter.
In the UK whistleblowers acting in accordance with The Public Interest Disclosure Act 1988 (PIDA)
are afforded protection.
Included in this guide is an example whistleblowing code that may be used as a basis for an
organisation’s own procedure. Because of the negative connotations that may be associated with
the word ‘whistleblowing’, the code has been titled ‘Speaking Up’.
Before implementing any code organisations should read the British Standards Institution’s (BSI)
Whistleblowing Arrangements Code of Practice available to download here:
http://www.bsigroup.com/en/Standards-and-Publications/Industry-Sectors/Risk/PAS-19982008Whistleblowing/
Public Concern at Work (PCA) also provides advice, support packages and training. Additionally,
they have a webpage dedicated to practical hints for small employers. Further information can be
found on their website:
http://www.pcaw.co.uk/
2
SMALL ORGANISATIONS
The BSI Whistleblowing Arrangements Code of Practice states:
A small organisation’s whistleblowing arrangements are best determined by its structure,
its culture and the nature of the risks it faces. There is no” one size fits all” approach to this
issue. For many small organisations, where the person in charge of the organisation knows
the workforce by name, there will often be no need to introduce a procedural or complicated
whistleblowing policy. Rather, in such organisations, it will be enough if those in charge give
an unambiguous statement that it is safe and accepted for staff to speak up if they have a
whistleblowing concern and that employees are reminded of this and given an opportunity
to discuss the arrangements at staff meetings annually.
In small organisations there will often be additional reasons to make clear:
(a) the difference between a whistleblowing concern and a private complaint;
(b) that employees and managers understand their role and that managers should not feel
undermined if they are by-passed;
(c) the difficulty of maintaining confidentiality;
(d) the benefits of an independent helpline; and
(e) how an employee can make an external disclosure.
3
ACCA LEGAL NOTICE
This is a basic guide prepared by the ACCA UK's Technical Advisory Service for members and their clients. It should not
be used as a definitive guide, since individual circumstances may vary. Specific advice should be obtained, where
necessary.
4
Model Code for Small and Medium Sized Owner Managed Businesses
The following model code sets out the basic requirements that a small or medium sized business
should adopt. At all times employees should be encouraged to report their concerns to the most
appropriate senior person within the business. When all other internal avenues have been exhausted
then an approach should be made to a major shareholder or partner.
The code should be modified appropriately for any specific business.
SPEAKING UP CODE
Speaking up
As a business/organisation we are committed to operating in an ethical and principled way. We
expect our employees and other stakeholders to do the same.
The ‘Speaking Up’ code has been put in place to assist employees to support us in our aims by
providing a safe, independent route by which you may raise any concerns you have about issues
that are not in accordance with our stated aims. To enable this scheme to work we look to our
employees to bring matters of concern about possible wrong, dishonest or illegal activity to the
appropriate individual within the organisation and it is to this end that the Speaking Up code has
been designed to help you in your role.
Issues that you may wish to report
The Speaking Up code provides an avenue to report instances of wrong, dishonest or illegal activity.
This might include waste or losses, error, mismanagement or dishonesty that may harm individuals
or our organisation. This may relate to people issues and/or business issues and it could involve
stakeholders.

People issues might include, for example, employees being treated in an unacceptable way –
bullied, threatened, subject to racist or sexual harassment or victimisation.

Business issues might involve, for example, dishonestly obtaining an advantage, avoiding an
obligation or causing a loss to another party (e.g. in dealings with stakeholders). It might
mean deliberately providing wrong information. It might also mean ‘fraud’ (a commonly
used term that includes activities such as theft, corruption, embezzlement, bribery and
extortion as well as conspiracy and deception).
We recognise that you may observe some behaviour and may be unsure whether it is inside
acceptable boundaries or not, and whether it is appropriate for you to use the Speak Up code. If you
5
are unsure, you can call [insert the person responsible for personnel issues] for (people issues) and
[insert the person responsible for internal risk management – possibly the money laundering officer,
accountant or the owner of the business] (for business issues) in confidence for advice.
Before making a report to the appropriate individual you may find it helpful to note down:

the nature of your concern or issue to be reported (e.g. theft, bullying)

reason for believing that what you are reporting is an issue

full name(s) of those involved. DO NOT APPROACH OR ACCUSE ANY INDIVIDUALS
DIRECTLY.

times and dates when it may have happened

details of the location concerning the issue

details of any evidence

has any action already been taken by anyone?

Details of any witnesses
Anonymous allegations
Under the Speaking Up code you are encouraged to identify yourself. Anonymity means that you
will not be able to receive feedback and it is also likely to make investigating a concern more
difficult. We will, however, consider anonymous reports according to:

the seriousness of the issues raised

the credibility of the concern

how likely it is that the concern can be confirmed from attributable sources.
Do not use the Speaking Up code for:

personal grievances

untrue allegations. We encourage you to speak up in good faith but we do not condone
malicious or vexatious allegations. Disciplinary action may be considered and implemented
against those who seek to abuse the code.
Privacy
We will respect your privacy if you raise a concern in good faith. There may be instances where it
becomes necessary to reveal the source of information and a statement may be required as part of
the evidence (for example, where an act of wrongdoing has been proven and a statement is
required for disciplinary proceedings or to mount a prosecution. In such an event we will support
you throughout the process.
Harassment or victimisation
You can be confident that we will not tolerate harassment or victimisation and will take action to
protect you when you raise a concern in good faith.
6
Who should I contact?
Everyone in our business, including members of the senior management team, is subject to the
same standards
and anyone who has concerns or issues relating to the [chief executive*] can speak in confidence to
[the major
shareholder*]
We encourage you to raise your concerns internally in the first instance as we provide a safe,
independent route
for you to raise your concerns within [the business]. As a last resort, if you feel you need outside
advice, you may
consider contacting the following external agencies which are able to provide support:

Employers’ confidential helpline (complete details as appropriate.)

Public Concern at Work (in the UK) is a charity that provide a free and strictly confidential
legal helpline
to anyone in the UK concerned about malpractice which threatens the public interest. There
is much
helpful information on their website: http://www.pcaw.co.uk/ . They also operate a helpline
on
020 7404 6609

your Trade Union - employees may ask their Trade Union to raise an issue on their behalf.

you may also raise suspicions of wrongdoing directly with the police.
If you seek advice outside [this business], you are reminded that you need to ensure that you do not
disclose
confidential information or that your disclosure would be protected by privilege. This can be
checked with Public
Concern at Work who will also advise on ways to proceed.
It is a condition of working for [this business] that you do not speak or write to representatives of
the press, TV,
radio, or to any other third party about concerns and issues without the express authority of the
chief executive.
Care must be taken to ensure that nothing is done that could give rise to legal action (e.g for
slander or libel) or
damage [the organisation's] reputation.
Contact numbers:
7
Owner*
Senior Partner*
Senior Director*
Major shareholder*
Employer's free confidential helpline (if provided)
Public Concern at Work
8
Reporting process
You have concerns or issues
Notes
about wrong, dishonest or
What should I report, what might I want to
illegal activity involving the
include? See body of text.
business.
Speak directly to person responsible for
Either/or
internal risk or person responsible for HR
where you need confidentiality and/or
independent advice.
Discuss with your line
If directors or senior management are the
manager or head of
subject of your concern contact RM or HR
department.
directly.
If concerns appear well
founded, line manager or
department head tells
individual responsible for
internal Risk Management
(RM)*
Discuss with
Person responsible for internal
person
RM records issue in log book.
responsible for
Issues log
internal risk
Management
*or person
responsible for
HR.
RM or HR consider need to
Log reviewed
discuss with owner*, senior
by owner/
partner or director and/or
senior
major shareholder*.
partner,
senior
director or
major
shareholder
as
9
appropriate*.
* or equivalent
10