Creating a Whistleblowing Policy

We understand it can be challenging to put all your practices into formal policies. As such we have developed a suite of policy templates that can support you in formalising your practices. These policy templates are designed to act as a guide on what early-stage companies, such as your own, should have in place. However, we look forward to hearing your thoughts and feedback on the feasibility of making these your own documents and meeting the standards we have suggested.

What is a Whistleblowing Policy?

A Whistleblowing Policy describes a company’s standards and processes in place to address key risks related to illegal or unethical wrongdoing and misconduct within an organisation.

This Whistleblowing Policy template focuses on the topics of fraud, financial mismanagement and intentionally erroneous financial reporting. The scope of a company’s Whistleblowing Policy may be expanded to cover any other malpractice and misconduct within the company.

As this policy directly affects all internal and external stakeholders, it should be clearly communicated and publicly available (e.g., on the company website). The policy should be regularly reviewed to reflect changes to internal operations, regulations, and the business environment.

How should I use the template?

This template presents a core structure alongside whistleblowing topics that are relevant to most companies. Each section offers specific instructions on what companies should include per topic and lists policy language they can adapt. Please note that the template is merely a starting point. Companies are expected to make changes to match their unique characteristics and structures, as well their language and style.

There are various criteria to consider when adapting the Whistleblowing Policy to your company’s specific circumstances. In this template, we provide guidance based on company maturity to create corresponding mechanisms that effectively implement the Whistleblowing Policy. We set higher expectations for more mature companies, which will vary depending on factors such as the complexity of the business, volume of revenue and the amount of funding that has been raised. While a mature company may sometimes be considered companies at Series C and beyond, these factors should all play a role in determining what would be appropriate for each company.

If there are standards and requirements which your company cannot meet, reach out to Integra for explanation and support.

Note that the template is merely a starting point! Some topics may be more important to you than others, and there may be topics that are unique to your company that the template doesn’t address. Use the template as a basis to make changes to match your characteristics and structures, as well as language and style.