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Whistleblowing

Whistleblowing is when an individual raises a concern about a danger, risk, malpractice or wrong doing within an organisation. The concern may be raised internally or externally.

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FRC UK Corporate Governance Code

The UK Financial Reporting Council (FRC) published the UK Corporate Governance Code, for listed companies in September 2012. This includes a provision on whistleblowing. 

Provision C 3.5 of the Code states:

"The audit committee should review arrangements by which staff of the company may, in confidence, raise concerns about possible improprieties in matters of financial reporting or other matters. The audit committee's objective should be to ensure that arrangements are in place for the proportionate and independent investigation of such matters and for appropriate follow-up action."  

Further Guidance

The ICAEW published its ‘Guidance for Audit Committees: Whistleblowing arrangements,’ in March 2004. This guidance was written when the Combined Code of Corporate Governance was in force. As its replacement, the UK Corporate Governance Code, imposes the same responsibility on the audit committee with regard to the whistleblowing arrangements in place in  a listed company, we continue to commend this material as it provides useful and accessible guidance on whistleblowing procedures for audit committees and non-executive directors.

Should I blow the whistle?

An individual in an organisation who is thinking about "blowing the whistle" will need to consider, amongst other things, how best to raise the concern in the public interest so that it will be properly addressed, while at the same time minimising any potential risk to himself.

In general, an individual in an organisation should discuss the matter internally first, using all appropriate channels, and then resort to going outside the organisation.

If you are concerned about possible misconduct, you might find the following considerations helpful in deciding how to proceed:

  • Is it a genuine concern or might there be an innocent explanation?
  • Who is affected and how?
  • What are the risks attached to the misconduct?
  • How serious or imminent are those risks?
  • Does the organisation have a whistleblowing policy?
  • What guidance and advice does the Institute provide? What is the risk of professional disciplinary action?
  • What are the options for raising the concern internally or externally?
  • Has the concern been raised and if so, how and who with? What was the response?
  • Are there any other options?
  • Is there legal protection for whistleblowing?

Where to get advice and assistance

Ethics Advisory Service

The Ethics Advisory Service can provide advice on the specific guidance that applies to members of the ICAEW via its helpline +44 (0)1908 248 258 or email ethics@icaew.com

Public Concern at Work (PCAW)

Public Concern at Work (PCAW) is a charity concerned with whistleblowing issues. Their helpline +44 (0)20 7404 6609 and email helpline@pcaw.co.uk offers free and confidential advice to anyone about misconduct at work who is not sure whether or how to raise their concerns. PCAW aims to help enquirers to identify how best to raise the concern while minimising any risk to the whistleblower and maximising the chances for the misconduct to be properly addressed.

The Law Society

You may want to seek legal advice on your position. The Law Society website is helpful in drawing up a shortlist of appropriate firms.

Why are whistleblowing procedures important?

Whistleblowing informs those who need to know about dangerous or illegal activities that affects others and gives them an opportunity to address the issue. Therefore, whistleblowing protects individuals and sometimes saves lives.

Setting up formal whistleblowing procedures within an organisation strengthens corporate governance and ethics in the organisation as well as being a useful risk management tool.

Whistleblowing procedures in an organisation encourages individuals to disclose concerns using appropriate channels before these concerns become a serious problem, damaging an organisation's reputation through negative publicity, regulatory investigation, fines and/or compensation.

Key documents

Accountants in business or practice may have statutory or contractual obligations to report to a regulator or other third party or to SOCA under the Anti-Money Laundering requirements. They may also whistle-blow to a third party where it would be in the public interest to do so, even they have no legal obligation to do so. This right is discussed in the Guidance Statement Professional conduct in relation to defaults or unlawful acts.

Guides and publications

Reading lists and links

Guides / Publications

ICAEW representations