When Zayd Khalid Maniar, Managing Partner at Crowe UAE, teaches ethics, he uses a very simple analogy to try to dispel certain ideas about whistleblowing: you’re walking down the street and you see a stop sign that’s fallen into disrepair, so you report it. That is whistleblowing in a nutshell. Quite often, his students disagree. “The way we have been conditioned is that whistleblowing is only very sexy, very high profile and very career defining,” says Maniar. “It’s not.”
Whistleblowing should be reframed, he says, as a service to the company and to the public at large. It’s beneficial; important for financial regulation and economic stability. It’s not all about huge, company-killing scandals.
“Not every whistleblowing incident needs to end up with the organisation diminishing or being destroyed,” Maniar says. “This is where training helps. People need to realise that if they blow the whistle about a problem, it will be duly investigated and corrected. Whistleblowing is not as glamorous or as ‘espionage’ as it sounds. It’s about corrective action that can come from somebody who’s seen something that’s gone wrong.”
Whistleblowing is expected of chartered accountants, under the new Code of Ethics, if they find evidence of unethical behaviour, As leaders in the space, this also means that they need to create and maintain a culture that encourages whistleblowing if the need arises. But there is still a perception that whistleblowing ends in negative press and can potentially damage the career of the whistleblower. This is at the extreme end of the spectrum.
To embed a positive culture that allows for people to come forward if something goes wrong, finance leaders need to create a sense of safety so that individuals feel they can report incidents without worrying about being stonewalled or punished by their superiors. The process needs to be very clear and communicated by leaders, says Maniar. They should be a sounding board if people have questions about that process. They should highlight independent sources of advice so that their people feel they always have someone to turn to.
It’s not about taking away accountability, he stresses, but making sure that employees know that they can continue to thrive in the organisation after reporting something. It’s crucial that it’s clear for everyone what will happen next if someone does blow the whistle.
“I’ve had conversations with people who have eventually gone on and blown the whistle and there has been confusion over what will happen. Will they end up in the witness box? Will their name appear in the papers the next day? Does the organisation get notified that they have done this? It’s where organisations can work with professional bodies to build robust processes that are simple and effective.”
This needs to go beyond assurances of confidentiality, Maniar stresses. “It’s about clarity about what comes next.”
Maniar has offered his expertise to a number of cases where whistleblowing resulted in the need for further assurance. He has observed that those organisations that are most successful recognise the benefits of whistleblowing and communicate it as a positive thing. “It's helping them mature, evolve and go beyond.”
He has observed several elements of good, whistleblowing-positive cultures.
Regular training
One of the critical levers to help embed a pro-whistleblowing culture is regular training. This should take place around once a year and should be based around scenarios and case studies to help employees consider how they might respond in similar situations.
“These might be real cases, or made up ones that represent common scenarios,” says Maniar. “It will help people understand processes.”
Transparency
Good ethical processes are based on transparency, Maniar says. When people share information as part of a whistleblowing procedure, it should be very clear where that information is going and how it might be acted upon. “You cannot say with certainty exactly what will happen because each case would require different actions,” he says. “But there should be an indication of likely next steps, and somebody should be in touch with the whistleblower to talk through their specific case.
Independent management
The person or people tasked with facilitating whistleblowing cases should be managed by someone independent from the organisation to avoid any conflicts of interest filtering into the process.
That independent person or organisation should keep in touch with the whistleblower from the beginning, outlining what is likely to happen, including to their job. In most cases, that job will be safe, but in others, it may be more complicated – for example, when someone reports something that they have done, often because they were coerced into it. “They can't continue that role, but they will want to know if they can find gainful employment elsewhere,” says Maniar.
Open and approachable leadership
Outside of that independent whistleblowing process, leaders should show themselves to be open and encourage open dialogue. This cannot be achieved overnight, says Maniar. “Simply putting it on our website or sending a memo saying: ‘Hey, if you come across anything, reach out to me’, that’s not going to work.”
People need to feel comfortable speaking about anything, good or bad. To achieve that, managers need to project a sense of openness and curiosity. “If you’re always on edge, crabby, annoyed, what are the chances that somebody’s going to come to you with a problem? Especially a problem that requires you to step forward and identify the causes of the problems, rather than just blaming somebody.”
Approachability is key, says Maniar. And while that sounds overly simplistic, it is actually the cornerstone of ethics. Difficult conversations are central to managing ethics, he adds, and leaders and managers in accountancy need to be prepared to have those conversations. They need to actively listen, with a calm and friendly demeanour. If you don’t have the time to talk at that particular time, he says, make sure you arrange another time.
Take an active interest in your staff in general. It will help build trust, and you may even notice when people are struggling, allowing you to take the initiative. “I’ve had conversations where an issue would usually be whistleblowing, but conversations had already been had at the right levels and were quickly appreciated and addressed, so there was no need. With the right culture and ethics, people will do the right thing.”
Celebrate ethics with ICAEW
To mark Global Ethics Day 2025 on 15 October, ICAEW is exploring what it means to lead with integrity in a rapidly evolving professional landscape.