We already wrote about which kinds of whistleblowing channels best fit your company’s needs. In this series of blogs we have a closer look at these two individual types of whistleblowing portals. We compare the pros and cons of whistleblowing through regular post with an internal mailbox for reporting wrongdoing.
Reporting via ordinary mail is in practice much less prevalent than reporting through other channels.
When setting up such a channel, clear instructions should be communicated to potential whistleblowers regarding to whom their letter reports should be addressed and whether any additional marking should be included next to the address (e.g. “Report – Do not open!).
Additionally, a process should be defined on how such reports are received and distributed within the organization in order to ensure their confidentiality and integrity.
When internal letterboxes are used as a reporting channel, the anonymity and confidentiality of their usage should be considered.
Hence, such letterboxes should not be in range of any security camera, placed in locations with high frequency or in clear view of other employees.
What is the EU Whistleblowing Perspective?
The EU Directive stipulates that channels for receiving the reports need to be designed, established and operated in a secure manner that ensures that the confidentiality of the whistleblower’s identity and any third party mentioned in the report is protected, and prevents access thereto by non-authorised staff members.
Internal reporting channels need to enable reporting in writing or orally, or both. Oral reporting shall be possible by telephone or through other voice messaging systems, and, upon request by the reporting person, by means of a physical meeting within a reasonable timeframe.
When a report is made in person the organization is required to ensure, subject to the whistleblower’s consent, that complete and accurate records of the meeting are kept in a durable and retrievable form. The meeting may be documented either by making a recording of the conversation or through accurate minutes of the meeting. In the latter case the whistleblower must be offered the opportunity to check, rectify and agree the minutes of the meeting by signing them. Similar provisions apply also when transcripts of reports received through recorded telephone lines or other recorded voice messaging system are prepared, or when a conversation with a whistleblower via unrecorded telephone line or other unrecorded voice messaging system is documented with minutes.
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