Whistleblower Policy (GCRCB)

  • Updated on Apr 29, 2025
  • Published on Apr 18, 2024
  • 6 minute(s) read
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How to use this policy

(1) Copy this template in its entirety and edit as necessary to align with your organizational context. (2) Remove the supplemental guidance text in blue boxes and replace the yellow highlighted text with the actual details of your organization.

Note: The content in the matrices below are best viewed on a desktop.

  1. Introduction

[Insert organization name] is committed to operating to the highest ethical standards. The purpose of this policy is:

  • to encourage employees, contractors, and other stakeholders to report concerns of suspected or actual instances of illegal, unethical, or inappropriate behavior or practices in the knowledge that their concerns will be taken seriously and investigated as appropriate, that their confidentiality will be respected wherever possible, and without fear of retaliation (even if they turn out to be mistaken);  

  • to provide staff with guidance as to how to raise those concerns.

  1. Scope

This policy covers all employees, officers, consultants, contractors, volunteers, interns, casual workers, and agency workers. This policy does not form part of any employee's contract of employment and may be amended  at any time. 

This policy aims to comply with the Whistleblowing protections under [UK law/US law], including relevant regulations such as the [Public Interest Disclosure Act 1998 (PIDA) / California Whistleblower Protection Act].

  1. Definition

Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to [Insert organization name] activities. It can also refer to refusing to participate in an activity that would result in a violation of a state or federal statute, or a violation of or noncompliance with a local, state or federal rule or regulation. Examples of reportable items are as follows:

  • criminal activity;

  • miscarriages of justice;

  • danger to health and safety;

  • damage to the environment;

  • failure to comply with any legal obligation;

  • the deliberate concealment of any of the above matters.

Whistleblowing generally only refers to raising a genuine concern relating to any of the above. This policy does not cover complaints relating to personal individual circumstances that are unrelated to the factors mentioned above (e.g. bullying, harassment, discrimination, complaints about working conditions, inter-employee conflicts, performance-related complaints, etc.). In these cases, the Grievance Policy should be used.

  1. Reporting Mechanisms

In general cases, individuals should raise any whistleblowing-related concerns with their direct supervisor. 

However, should there be a preference not to discuss such matters with their supervisor for any reason, individuals are encouraged to contact the Whistleblowing Officer [insert name of officer, usually the chief executive] or a member of the senior management team.

Contact details are detailed below:

NAME

DESIGNATION

EMAIL ADDRESS

PHONE

[insert name of officer]

Whistleblowing Officer

[insert email]

[insert phone]

…




…




You may also use these confidential [Insert organization name] whistleblowing hotlines:

NAME

CONTACT

Confidential Whistleblowing Hotline (Email)

[insert email]

Confidential Whistleblowing Hotline (Phonel)

[insert phone number]

…



A meeting will be arranged with the concerned party at the earliest convenience to discuss. 


  • The individual has the right to be accompanied by a colleague or a union representative during any meeting conducted under this policy. Such companions must respect the confidentiality of the disclosure and any investigations that follow.

  1. Investigation

See procedures for handling investigations below: 

  1. Initial assessment

    Upon receipt of a whistleblowing concern, the company commits to a thorough initial assessment to determine the necessary immediate actions or further investigations required.

  2. Communication with the whistleblower

    The whistleblower will be promptly informed of: 

    • The designated individual handling their concern;

    • Methods of communication with the handler;

    • Whether additional assistance from the whistleblower is needed;

    • Upon request, a written summary of the concern, the approach for addressing it, and the anticipated time frame for a response, if feasible.

  3. Handling and Documentation

    The appointed individual responsible for responding to the allegation will:

    • Decide on the preliminary course of action;

    • Ensure the decision and subsequent steps are effectively and quickly communicated and recorded. All concerns and the steps taken to address them will be documented thoroughly;

  • [Insert organization name] will provide updates to the whistleblower regarding the status of their concern and the outcome of any investigations, within the bounds of confidentiality and legal constraints.

  • While striving for transparency, it may not always be possible to disclose specific actions taken if it compromises a duty of confidentiality to another party. The procedure will remain as transparent as possible within these limitations.

Should further investigation be necessary:

  • The Whistleblowing Officer may assign a team or individual with relevant expertise or specialized knowledge;

  • The whistleblower might be invited to meetings to provide additional information.

While [Insert organization name] cannot guarantee the outcome desired by whistleblowers, it pledges to address each concern fairly and appropriately. 


  1. Confidentiality

[Insert organization name] aims for all staff members to feel empowered to openly express whistleblowing concerns under this policy. However, anonymous disclosures may be more difficult to investigate thoroughly.


Should an individual wish to raise a concern confidentially, every effort will be made to maintain the confidentiality of their identity, disclosing it only to those directly involved in the investigation of the concern, and only as necessary.

  1. External Disclosures

The aim of this policy is to provide an internal mechanism for reporting, investigating, and remedying any wrongdoing in the workplace. In most cases, reporting to external parties and authorities is unnecessary.

However, the law recognizes that in some circumstances it may be appropriate to report concerns to an external body (e.g. law enforcement, regulators, etc.). [Insert organization name] strongly encourages all potential whistleblowers to seek legal advice before reporting a concern to external parties. 

[For UK organizations]

Protect (formerly Public Concern for Work)


[For US-based organizations] 

OSHA (Occupational Safety and Health Administration) 

GAP (Government Accountability Project)


[For US & California-based organizations] 

California State Attorney General

  • CA AG Line: +1 (800) 952-5225 or +1 (916) 210-6276

The Attorney General will refer your call to the appropriate government authority for review and possible investigation.

California State Auditor

  1. Protection and Support for Whistleblowers

[Insert organization name] encourages openness and will support whistleblowers who raise genuine concerns under this policy, even if they turn out to be mistaken.


Whistleblowers must not suffer any detrimental treatment as a result of raising a genuine concern. Detrimental treatment includes dismissal, disciplinary action, threats, unfavorable employment actions such as location transfers or changes in job duties, or other unfavorable treatment connected with raising a concern. 


If retaliation against a whistleblower is suspected, the Whistleblowing Officer must be informed immediately. If the matter is not remedied with the appropriate urgency, the concerns should be raised formally using the grievance procedures found in the Grievance Policy.


All those involved that threaten and retaliate against active or potential whistleblowing may be subject to disciplinary action, as well as legal and regulatory protections as necessary. However, should the whistleblower make false allegations maliciously, the whistleblower may be subject to legal or organizational penalties.

  • [For US & California-based organizations] Under California Labor Code Section 1102.5, if an employer retaliates against a whistleblower, the employer may be required to reinstate the employee’s employment and work benefits, pay lost wages, and take other steps necessary to comply with the law.

Any personal data processed under this policy will be processed in accordance with applicable data protection legislation and [Insert organization name] data protection policies.

  1. Accountability & Role of Staff

The Whistleblowing Officer has operational responsibility for this policy, and must ensure that staff (especially managers) who may deal with concerns or investigations under this policy receive regular and appropriate training.


All staff are responsible for the success of this policy, and should use it to disclose any suspected danger or wrongdoing.

  1. Amendments & Additions

This policy will be reviewed annually and may be amended as necessary to address new ethical challenges and evolving standards. 

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