Introduction

Whistleblowing enables early detection of corruption, fraud and misconduct affecting financial integrity, human rights and the environment. Internal whistleblowing systems (IWS) reduce legal, financial and reputational risks while supporting ESG objectives and fostering organisational transparency and accountability.

Objective of this framework

The framework provides indicators and guidance to monitor, evaluate and report on IWS effectiveness. It supports organisations, regulators and compliance professionals in improving whistleblower protection, data collection and governance practices across sectors.

Continuous monitoring and review

Ongoing monitoring using data on reports, retaliation and staff perceptions helps identify risks and system gaps. Low reporting may indicate low awareness, while out-of-scope reports suggest training needs. Disaggregated data highlights disparities and supports system improvements.

Transparency and accountability to stakeholders

Publishing whistleblowing data builds trust and demonstrates accountability. Reporting outcomes and trends reassures stakeholders, addresses fear of inaction and strengthens a “speak up” culture, while supporting ESG and risk management expectations.

Collecting data and preparing the report

Data collection must ensure confidentiality, accuracy and accessibility. Organisations should use secure systems, standardised processes and clear reporting formats, aligning with legal and ESG requirements while enabling meaningful analysis.

Key principles guiding data collection and reporting

Core principles include confidentiality, data integrity, accessibility and inclusivity. Aggregation and anonymisation reduce identification risks. Disaggregated data supports analysis of systemic inequalities while maintaining protection of whistleblowers.

Understanding reporting requirements

Organisations must comply with whistleblowing, data protection and sector-specific regulations. Alignment with standards such as ISO 37002 and ESG frameworks ensures consistent, reliable reporting and strengthens governance.

Roles and responsibilities in data collecting and reporting

Senior leadership oversees IWS effectiveness. Whistleblowing officers manage data, reporting and coordination across functions, ensuring accurate, comprehensive and accountable reporting processes.

Understanding the report’s audience

Reports should be tailored to stakeholders. Leadership requires strategic insights on risks and performance, while personnel need clarity on protections. External audiences, including investors and regulators, focus on governance and risk indicators.

Publication and promotion

IWS reports should be publicly accessible and communicated through multiple channels. Annual reporting, integration into governance disclosures and internal communication enhance visibility and engagement.

The IWS Report

Effective reports include legal context, system scope, resources, leadership commitment and detailed data on reports, outcomes and impacts. Confidentiality statements and clear methodologies are essential.

Part I – Establishing the framework

This section outlines legal requirements, IWS scope and resource allocation, including staffing, budgets and technology, highlighting organisational commitment and potential gaps.

Part II – The value of whistleblowing

Whistleblowing supports ethical conduct, risk prevention and public trust. Leadership endorsement reinforces its importance and promotes a culture of transparency and accountability.

Part III – Data on reports

Reporting should include volumes, types of wrongdoing, outcomes, financial impacts, retaliation cases and satisfaction levels. Data should be aggregated, anonymised and analysed for trends and system performance.

Part IV – The impact of whistleblowing on the organisation

Whistleblowing contributes to improved risk management, policy changes, cost savings and prevention of harm. Case studies demonstrate organisational and public benefits.

Monitoring framework

The framework provides structured indicators to assess IWS performance, including reporting activity, outcomes, trust levels and resource allocation, enabling consistent evaluation and benchmarking.

Indicators on reports of wrongdoing

Metrics include number of reports, reporting channels, types of wrongdoing, follow-up actions, resolution times and financial impacts such as recovered assets and avoided losses.

Indicators on complaints of detrimental conduct linked to whistleblowing

Indicators track retaliation complaints, types of detrimental conduct, outcomes, remediation actions and resolution times to assess whistleblower protection effectiveness.

Indicators on awareness of and trust in the organisation’s IWS

Survey-based metrics assess training coverage, reporting willingness, trust levels and experiences of retaliation, highlighting cultural and behavioural factors.

Indicators on the organisation’s resources for the operation of its internal whistleblowing system

Resource indicators cover staffing levels, training, budgets, external support and technological tools, enabling evaluation of system capacity and effectiveness.