The implementation of an internal channel for whistleblower complaints plays a key role in promoting business ethics and transparency in organisations. In a corporate group, where different companies collaborate and share resources, proper management of internal whistleblowing becomes even more crucial.

Organisational structures can be complex, with multiple entities operating under a holding entity. Such a situation can increase the likelihood of improper or fraudulent activities. An effective internal whistleblowing procedure should be clear, accessible, and confidential. It should enable institutions and their subsidiaries to investigate unlawful acts. Along with this, the confidentiality and privacy of the whistleblower should always be safeguarded.

Although the regulation of whistleblowing channels has a European legislative basis, each country specifically regulates these situations in groups of companies, so that in some countries it is the holding company of a group of companies that has to approve a general internal whistleblowing policy.

Coordination between the different entities of a group is essential to ensure that internal whistleblowing complaints are managed effectively and consistently across all group companies. In any case, a group of companies should consider the following aspects for the proper management of internal whistleblowing.

How Should Whistleblower Complaints Be Managed in Groups of Companies?

Common Policies and Procedures: It is beneficial for all group companies to adopt common policies and procedures for internal whistleblowing. This ensures uniformity in the management and processing of whistleblowing complaints.

Centralised Coordination: Consider establishing a centralised coordinating entity to oversee internal complaints across the group. This can be particularly useful in large and diversified corporate groups.

Internal Communication: Internal communication is key. Therefore, employees in all group companies should be aware of the reporting channels and how their reports will be managed.

Confidentiality and privacy: Regardless of who manages the whistleblowing procedures, whistleblowing must be conducted in a way that ensures the anonymity of the whistleblower and the confidentiality of the reported facts.

The management of internal whistleblowing within a corporate group is a critical element in promoting business ethics and transparency. This is especially true in groups with offices in different countries. Coordination is essential to ensure consistent and efficient management across all group companies.