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How to deal with a whistleblowing complaint

Author: ICAEW Insights

Published: 07 Apr 2025

Whistleblowing is a vital tool to tackle corruption and other criminal offences. When an employee approaches an employer with a concern, whether anonymously or not, it is vital to handle it with expediency and delicacy.

Whistleblowers’ disclosures have exposed wrongdoing and fraud, helping save millions in public funds and avoiding health and environmental disasters. Their important role in safeguarding the public good is repeatedly proved by the myriad scandals they uncover.

Whistleblowing is never straightforward, however. It often puts an employee in a stressful and sometimes isolating situation. Therefore it’s vital to handle the process with great care. In recent years, more and more employers have established whistleblowing policies or instilled a ‘speak up’ culture, even though there is no legal requirement in the UK to do so. The existence of a whistleblowing policy shows an employer’s commitment to listening to the concerns of workers, and that it welcomes information being brought to the attention of management.

When dealing with a whistleblowing complaint in accountancy, it’s vital to take the concern seriously, investigate thoroughly and objectively, maintain confidentiality, and follow established internal procedures while following relevant regulations such as the Public Interest Disclosure Act. If the complaint involves serious financial misconduct, managers should consider reporting it to the appropriate regulator – such as the Financial Reporting Council – alongside internal investigations. 

They should follow a clear process and communicate it to all stakeholders. Gathering evidence will be vital to support any investigation. This might involve interviewing relevant parties – including the whistleblower, accused individuals, and any potential witnesses – in a fair and respectful manner. 

“Whistleblowing is more than just reporting malpractice,” says Joanna Lewis, Managing Director at Safecall, which provides whistleblowing solutions for employers. “It’s a step towards ensuring no one else is impacted by the action, whatever it may be. A whistleblowing concern is something that affects not only the person who raises it, but other employees and the workplace, and when a concern arises, it’s important to go through the appropriate channels.”

Whether a whistleblowing report comes from inside or outside the company doesn’t change the seriousness of the claim. Internal complaints should be handled with just as much care as external ones. It’s critical to train managers on whistleblowing procedures and how to respond to disclosures. If employees don’t trust their company to act, they will go straight to regulators or the media and that’s when things can spiral into public scandal. It’s in a company’s best interest to have a process that allows employees to speak up before it reaches that point.

Nigel Layton, Global Head of Pharma & Life Sciences and the UK Head of Investigations, Forvis Mazars, says: “In today’s world, where culture, behaviour and the company’s reputation are paramount and where there are increasing expectations of an open and honest culture in a business, employees need to be able to feel they can speak up when they need to without recrimination.

“Having a formal whistleblowing channel or speak up line therefore helps a company adhere to its culture and values statement and ensure that it operates legally and ethically.”

Communication is key to the process. When someone blows the whistle the organisation must explain its procedures and outline whether the whistleblower can expect to receive any feedback, and when. Feedback is vital so that whistleblowers understand how their disclosure has been handled. Often a whistleblower may expect to influence any action the organisation might take. These expectations must be well managed. Once the investigation is complete, managers should present findings clearly to relevant stakeholders, including senior management. 

“As workers, partners and office holders have protection once they have made a complaint, businesses need to ensure that whistleblowers are treated appropriately. Having a whistleblowing policy in place helps to protect the business and the whistleblower,” says Helen Farr, employment partner at law firm Taylor Wessing.

Silence can be dangerous for the reputation of a business, says Georgina Calvert-Lee, Senior Consultant at Bellevue Law. Meaningful training and awareness programmes provide employees with the necessary confidence to know that concerns will be handled properly and fairly. It also protects the organisation by helping to catch issues early before they escalate into serious legal or reputational damage.

“Whistleblowing is often about more than just policies; it’s about culture,” Calvert-Lee says. “Organisations that encourage openness and act on concerns can avoid crises before they happen. Good leaders foster a culture where everyone feels safe to play a part and speak up when something doesn’t seem right.” 

David Gomez, Senior Adviser, Ethics, ICAEW, agrees. “Part two of the Code of Ethics mandates all professional accountants to promote an ethical culture within their organisations and to exhibit ethical behaviour in dealing with individuals with whom, and entities with which, they or the firm have a professional or business relationship. 

“Creating ‘psychological safety’ in the workplace is part of this. Empowering employees to speak up, ensuring that they fully understand the process and mechanisms for doing so, and demonstrating that any concerns raised are both valued and listened to, and that prompt action has been taken to address them, are essential ingredients of an ‘ethical culture’.”

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