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How to Implement a Whistleblowers Policy

In my personal experience as a forensic fraud investigator, there is one question that clients ask me time and time again. "Should we implement a whistleblower strategy?"

You can probably guess my answer...

So why should you implement a whistleblower policy?

Simply put, a whistleblower portal provides a platform for employees, ex or current, the opportunity to 'comfortably' provide tip-off information that may never have come to light otherwise. By providing this avenue you are helping people to disclose their concerns freely, confidentially and without fear of retribution.

In short, when used correctly and trusted by your employees, this reporting mechanism is a progressive and effective way to gather information and intelligence on theft, criminal activity, corruption and any number of dishonest actions playing out in your business.

The truth is, without a trusted and discreet way of reporting criminal actions a vast percentage of employees will simply turn a blind eye or continue to remain mum on the issue. My experience with this form of tip-off is almost always accurate. For the most part, my involvement with company fraud cases has stemmed directly from a whistleblower report.

The benefits a trusted whistleblower policy

To all those responsible for company security and loss control services, I recommend that you talk to your management team or clients about the benefits of such a system.

To help you motivate your argument for its implementation I will share some very strong arguments benefits with you:

  • Exposing wrongdoing, theft and fraud much earlier than would normally be the case. This alone is worth the cost to implement. Any investigator knows that much of their success relies heavily on time elapsed since crime was committed. Secondly, it is obvious but I'll say it anyway, the sooner you can learn about a fraud or dishonest action the more you minimise the loss incurred.
  • The very existence of a reporting avenue translates into creating doubt in the minds of those tempted to commit theft or fraud. This alone makes it a real asset in your overall defense portfolio.
  • Promotes internal accountability. 
  • Goes a long way in showing that the company is dedicated to fraud prevention and honesty in the workplace.

Problems that can come with a whistleblower policy

Just like all tip-off lines, boxes, etc. there will always be those individuals or groups (trade unions) for example who abuse the system to promote a hidden agenda, or to cast suspicion in another direction.

I have encountered many such abuses of the system, but with an experienced investigator overseeing the reports, companies can quickly pick up on malicious or untrue reports. Unfortunately, this is the down side of having a whistleblower system in place.

Ensuring buy-in from employees 

My experience with whistleblower implementation is that it must be accepted and fully understood by all. I always advise my clients to make as much effort as possible to include all employees in the process leading up to implementation.

I find this is easiest done by choosing a project manager, and then identifying a working group representative of alł departments in the company.

Commitment to an ethical work culture 

Simply put, without a code of ethics and conduct your whistleblower system is dead in the water.
Every single employee, bar none, must be aware of your company's clearly defined behaviour policies. Issues such as fraud, theft, corruption, intimidation or related unethical behaviour must be well defined and shared in your code of conduct.

This code must be then incorporated into the whistleblower policy.

Investigation procedures 

Always keep in mind that you are not to ‘shoot the messenger’. The focus must always be on the message. Try your utmost to keep the whistleblower updated and advise promptly and regularly on what action has been taken (or not) and why.

Please ensure that your investigator is a thorough professional and understands the significance of discretion and unbiased opinion. Every single case must be filed and kept securely in case of future need.

Promoting the whistleblower policy

A well designed and carefully built policy means squat, if it ends up in some HR manager’s desk draw. The success of any information driven loss control system relies on it being at the forefront of people's minds, constantly.

Circulate and, even more importantly, don't be discouraged from sending out flash reports, once an investigation is wrapped up. Once employees see that the system is actually working the way they were told it would work, they will begin to buy into and trust it.


Always, always, always - and one more time for good measure ALWAYS - protect the identity of the whistleblower. Exposing your source will sink your employees’ trust in the system quicker than the Titanic.

You may even find that your investigation team or forensic investigators will have to come up with some very ingenious strategies to complete the investigation, just to ensure that the whistleblower’s identity is protected (another reason that your company must invest in absolute professionals when it comes to hiring investigators).

For more information on implementing your own whistleblower policy, contact saint@intrigue.co.za / 082 820 5363.

About D & K Management Consultants CC

Established in 1993 by Declan and Kyle Condon – the legacy of the Condon family with their many years of investigative expertise still strongly governs the running of the company today.

Phone: 082 820 5363

Email: saint@intrigue.co.za