Having an appropriate whistleblower channel protocol in place is essential to ensure transparency and regulatory compliance in companies. However, the implementation and elaboration of this protocol raise doubts. Especially when the regulations do not specify details on its registration or notification to the competent authorities. Let’s see how to create this vital tool for the corporate social responsibility policy and ensure its effectiveness.

What is the whistleblower channel protocol?

The whistleblower channel is a tool that allows the submission of complaints or reports of irregularities or non-compliance within an organization. It is an avenue that guarantees the confidentiality of the reporter, often referred to as a ‘.whistleblower‘ or informant. This channel is regulated by Law 2/2023 which establishes the need for an internal information system in companies with more than 50 employees. Above all, establishing a clear whistleblower channel protocol is essential for regulatory compliance.

Whistleblower Channel Protocol

Creation of the Protocol

To create an efficient whistleblower channel, it is first vital to decide on its implementation. The Corruption Whistleblower Protection Act indicates that the management body is responsible for this decision. Once taken, it is essential to design the channel taking into account confidentiality. Most importantly the method of presenting the information and adequate protection of the informant.

The choice between an internal and external reporting channel is free. However, some organizations may opt for a external complaints channel to ensure impartiality and data protection, especially within the framework of the Data Protection Officer (DPO) and the compliance officer.

Content of the Protocol

The protocol must be clear and specific:

  • Introduction: Company name, regulatory framework and reasons for implementation.
  • Purpose: Purpose of the channel.
  • Scope of application: Definition of to whom it applies.
  • Guarantees: Protection for both the whistleblower and the reported.
  • Procedure: Details on how complaints are submitted, processed and investigated.

An essential component of this protocol is the Responsible for the Management autonomous figure who ensures the proper functioning of the channel.

Dissemination and Registration

Although an official register is not required, Law 2/2023 indicates that it is essential to have an internal register of the information received. In addition, the protocol must be accessible to all employees and stakeholders.


Finally, transparency and compliance are essential in the modern era. Effective implementation of a whistleblower channel ensures that companies not only adhere to regulations but also protect those who seek to do the right thing.

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