Internal whistleblowing process in a company is a crucial mechanism for identifying and addressing misconduct, fraud or ethical violations. Whistleblowing legislation sets out clear guidelines on how organisations should handle whistleblowing, and within this framework, senior managers and directors play a key role in investigating these allegations.

We discuss below the characteristics that should guide any senior manager in a company when an internal whistleblowing allegation arises:

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Commitment and accountability

Senior managers and directors are responsible for leading and overseeing the investigation of internal whistleblowing in a company, ensuring that it is conducted in an impartial and transparent manner. Their commitment to ethics and integrity becomes even more vital in this process, as they set the tone at the top and model the expected behaviour for the rest of the organisation.

Respect for the investigation process

The European whistleblowing directive highlights the importance of a structured and efficient process for investigating internal whistleblowing. Senior managers and directors should ensure that clear procedures are in place to receive, assess and deal with complaints in a confidential manner. This implies the creation of a competent investigation team and the adequate allocation of resources (either to fund specific platforms for managing the whistleblowing channel, for example).

Whistleblower protection

One of the key issues is whistleblower protection. Senior managers and directors should ensure that measures are in place to safeguard whistleblowers, avoiding retaliation and ensuring their anonymity wherever possible. Creating a safe environment for whistleblowing is essential to foster transparency and accountability.

Collaboration with competent authorities

In cases requiring the intervention of external authorities, senior management should cooperate fully with them. European whistleblowing regulations strongly establish the need to cooperate with competent authorities, ensuring that relevant information is shared in a timely and complete manner, and that this information does not manage to leak both inside and outside the company.

Transparent communication

Transparent communication is essential throughout the investigation process. Senior managers and directors should inform relevant stakeholders about the progress of the investigation without compromising its integrity. Effective communication contributes to maintaining trust both internally and externally and demonstrates the company’s commitment to accountability.

Implementing the appropriate measures for the case

After completing the investigation, senior managers and directors should take effective corrective action. This may include disciplinary sanctions, changes in internal policies or even adjustments in organisational culture. The whistleblowing regulation emphasises the need to act proportionately and fairly, considering the specific circumstances of each case.

Internal compliance culture

Senior management has a responsibility to cultivate an ongoing compliance culture in the company. This involves the implementation of training programmes, the periodic review of policies and the promotion of ethical values. A strong compliance culture not only prevents misconduct, but also strengthens the organisation’s resilience to potential ethical challenges.

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