Is a Whistleblowing Policy a legal requirement for UK employers?

There is no general statutory requirement in the Employment Rights Act 1996 or the Public Interest Disclosure Act 1998 for all employers to have a written Whistleblowing Policy. However, certain categories of employer are required to have one. In the financial services sector, the Financial Conduct Authority (FCA) rules (SYSC 18.3 and 18.4) require firms to have appropriate internal procedures for handling workers' disclosures and to inform UK-based employees of the FCA whistleblowing service. NHS bodies are required under their standard contract to have a whistleblowing policy. Public sector organisations are expected to have whistleblowing arrangements in place as a matter of good governance. For all other employers, ACAS strongly recommends having a written Whistleblowing Policy as part of good employment practice. A written policy demonstrates an organisation's commitment to transparency and ethical conduct, provides workers with a clear process for raising concerns, and helps protect the organisation from liability by showing that it has taken reasonable steps to address wrongdoing. The absence of a policy may also be taken into account by an Employment Tribunal when assessing claims of detriment or unfair dismissal connected to whistleblowing.

What is a qualifying disclosure under the Employment Rights Act 1996?

Under s.43B(1) of the Employment Rights Act 1996, a qualifying disclosure is a disclosure of information which, in the reasonable belief of the worker making it, is made in the public interest and tends to show one or more of the following: (a) that a criminal offence has been committed, is being committed, or is likely to be committed; (b) that a person has failed, is failing, or is likely to fail to comply with any legal obligation to which they are subject; (c) that a miscarriage of justice has occurred, is occurring, or is likely to occur; (d) that the health or safety of any individual has been, is being, or is likely to be endangered; (e) that the environment has been, is being, or is likely to be damaged; or (f) that information tending to show any of the above has been, is being, or is likely to be deliberately concealed. The worker does not need to prove that the wrongdoing occurred — a reasonable belief is sufficient. The public interest requirement, introduced by the Enterprise and Regulatory Reform Act 2013 s.17, was considered by the Court of Appeal in Chesterton Global Ltd v Nurmohamed [2017] EWCA Civ 979, which held that a disclosure can be in the public interest even where the worker also has a personal interest in the matter, provided the worker has a reasonable belief that the disclosure serves the public interest.

Who are prescribed persons and when can a worker disclose to them?

Prescribed persons are external bodies and regulators listed in the Prescribed Persons Order 2014 (SI 2014/2418), made under s.43F of the Employment Rights Act 1996. Under s.43F, a qualifying disclosure made to a prescribed person is a protected disclosure if the worker reasonably believes that the relevant failure falls within any description of matters in respect of which the person is prescribed, and that the information disclosed and any allegation contained in it are substantially true. Prescribed persons include the Health and Safety Executive (for health and safety matters), the Financial Conduct Authority and Prudential Regulation Authority (for financial services), the Care Quality Commission (for health and social care), the Environment Agency (for environmental matters), the Information Commissioner's Office (for data protection), HM Revenue and Customs (for tax matters), the Serious Fraud Office (for serious fraud), the National Crime Agency (for organised crime), and many others. The full list is maintained by the Department for Business and Trade. Workers do not need to exhaust internal procedures before making a disclosure to a prescribed person, though employers may encourage internal reporting first. Under the Prescribed Persons (Reports on Disclosures of Information) Regulations 2017, most prescribed persons are required to publish annual reports on the number of disclosures received and the actions taken.

Can a worker be disciplined for making a whistleblowing disclosure that turns out to be wrong?

No, provided the worker had a reasonable belief that the information disclosed tended to show one of the categories of wrongdoing listed in s.43B of the Employment Rights Act 1996 and that the disclosure was made in the public interest. The protection under Part IVA of the ERA 1996 does not require the worker to prove that the wrongdoing actually occurred. It is sufficient that the worker reasonably believed, at the time of making the disclosure, that the information tended to show wrongdoing. This means that a worker who raises a genuine concern in good faith is protected even if the concern is subsequently found to be unfounded after investigation. Disciplining a worker for raising a concern that was made in good faith and in the reasonable belief that it was in the public interest would itself constitute a detriment under s.47B and could give rise to a claim in the Employment Tribunal. However, the protection does not extend to workers who make disclosures that they know to be false at the time of making them. An employer may take disciplinary action, up to and including dismissal, against a worker who deliberately makes a false or malicious allegation. The distinction between a genuine but ultimately unfounded concern and a deliberately false allegation is critical and must be carefully assessed.

Whistleblowing Policy (UK)

Q: What protection does a whistleblower have against dismissal and detriment?

The Employment Rights Act 1996 provides two principal protections for workers who make protected disclosures. First, under s.47B, a worker has the right not to be subjected to any detriment by any act, or any deliberate failure to act, by their employer done on the ground that the worker has made a protected disclosure. Detriment includes any action that puts the worker at a disadvantage, such as denial of promotion, unfavourable changes to duties, disciplinary action, suspension, bullying, or isolation. Second, under s.103A, an employee who is dismissed shall be regarded as unfairly dismissed if the reason or principal reason for the dismissal is that the employee made a protected disclosure. This is known as automatic unfair dismissal — there is no minimum qualifying period of continuous employment to bring a claim (unlike ordinary unfair dismissal, which requires two years under s.108), and compensation is uncapped. The burden of proof differs depending on the type of claim: for s.47B detriment claims, the burden is on the employer to show the ground on which the act or deliberate failure to act was done; for s.103A dismissal claims, the burden is on the employer to show the reason for dismissal where the employee has sufficient evidence to raise the inference.

Whistleblowing Policy

Public Interest Disclosure Act 1998 — Employment Rights Act 1996 Part IVA

[Company Name]

[Company Street], [Company City], [Company Postcode]

Effective Date: [Policy Date]

1. INTRODUCTION AND SCOPE

1.1 [Company Name] is committed to operating with integrity and transparency. We recognise that all organisations are vulnerable to malpractice, wrongdoing, or illegal activity, and that those who work within or alongside an organisation are often the first to become aware of such concerns.

1.2 This Whistleblowing Policy is designed to encourage workers to speak up when they have genuine concerns about wrongdoing, without fear of suffering any detriment as a result. It explains what whistleblowing means, the protections available to whistleblowers under law, how to raise a concern, and how [Company Name] will respond.

1.3 This policy applies to all individuals working for [Company Name] in any capacity, including: employees (including home workers and agency workers); workers and contractors; self-employed persons engaged by [Company Name]; former employees where permitted by law; suppliers and business partners where relevant; and any other person who has a legitimate concern to raise in connection with the business of [Company Name].

1.4 This policy does not replace or override other [Company Name] policies, including the Grievance Policy, which should be used by employees who have personal employment-related complaints.

2. WHAT IS WHISTLEBLOWING?

2.1 Whistleblowing is the act of reporting information about suspected wrongdoing, malpractice, or illegal activity that is in the public interest. It differs from a personal grievance (such as a complaint about an individual's own employment situation) in that it concerns matters that affect others or the public at large.

2.2 A whistleblowing disclosure is sometimes called a 'protected disclosure'. Under the Employment Rights Act 1996 (ERA 1996), as amended by the Public Interest Disclosure Act 1998 (PIDA 1998) and the Enterprise and Regulatory Reform Act 2013 (ERRA 2013), a protected disclosure is a disclosure of information which, in the reasonable belief of the worker making the disclosure, is in the public interest and tends to show one or more of the following specified types of wrongdoing (known as 'qualifying disclosures').

2.3 Concerns raised under this policy will be dealt with sensitively and with discretion. [Company Name] encourages workers to put their name to any concern they raise, as anonymous concerns can be harder to investigate and workers who report anonymously do not benefit from the statutory protections described in section 8 of this policy.

3. QUALIFYING DISCLOSURES — WHAT CAN BE REPORTED

3.1 Under s.43B of the Employment Rights Act 1996, a qualifying disclosure is a disclosure of information that, in the reasonable belief of the worker, tends to show one or more of the following:

A criminal offence has been committed, is being committed, or is likely to be committed.
A person has failed, is failing, or is likely to fail to comply with any legal obligation to which that person is subject.
A miscarriage of justice has occurred, is occurring, or is likely to occur.
The health or safety of any individual has been, is being, or is likely to be endangered.
The environment has been, is being, or is likely to be damaged.
Information tending to show any of the above has been, is being, or is likely to be deliberately concealed.

3.2 Following the Enterprise and Regulatory Reform Act 2013 s.17, a qualifying disclosure must also be made in the reasonable belief that the disclosure is in the public interest. The Supreme Court in Chesterton Global Ltd v Nurmohamed [2017] UKSC 38 confirmed that workers need not quantify the number of members of the public affected, but must have a reasonable belief that the disclosure tends to show wrongdoing and is in the public interest.

3.3 Workers do not need to be certain that wrongdoing has occurred — a reasonable belief is sufficient. Workers will not be penalised if a concern is raised in good faith and subsequently turns out to be unfounded. However, workers who make deliberately false disclosures may be subject to disciplinary action.

3.4 Examples of concerns that may be raised under this policy include: fraud, bribery, or financial irregularity; health and safety risks; environmental breaches; cover-up of wrongdoing; regulatory non-compliance; and criminal activity.

4. PROTECTED DISCLOSURES — STATUTORY FRAMEWORK

4.1 This policy has been prepared in compliance with the following legislation:

Employment Rights Act 1996 Part IVA (ss.43A-43L) — which sets out the categories of protected disclosure and the conditions under which workers are entitled to protection against detriment and dismissal.
Public Interest Disclosure Act 1998 — which inserted Part IVA into the ERA 1996 and established the framework for whistleblowing protection in the United Kingdom.
Enterprise and Regulatory Reform Act 2013 (ss.17-20) — which introduced the public interest requirement for protected disclosures and extended protection to disclosures made to certain prescribed persons.
Prescribed Persons Order 2014 (SI 2014/2418) — which lists the prescribed persons and bodies to whom workers may make a protected disclosure, together with the matters in respect of which they are prescribed.
Prescribed Persons (Reports on Disclosures of Information) Regulations 2017 — which require prescribed persons to publish annual reports on their handling of whistleblowing disclosures.

4.2 Under s.43A of the ERA 1996, a worker who makes a protected disclosure is referred to as a 'protected disclosure worker' and is entitled to the protections set out in Part IVA, including protection against detriment (s.47B) and protection against automatic unfair dismissal (s.103A).

5. HOW TO RAISE A CONCERN

5.1 Workers are encouraged to raise concerns as soon as possible. There is no requirement to wait until a concern is proven. It is sufficient that a worker has a reasonable belief that wrongdoing has occurred, is occurring, or is likely to occur.

5.2 A concern should normally be raised in the first instance with the designated Whistleblowing Officer:

Name: [Officer Name]

Title: [Officer Title]

Email: [Officer Email]

Telephone: [Officer Phone]

5.3 Where a concern relates to the designated Whistleblowing Officer, or where a worker does not feel comfortable approaching that person for any reason, the concern may alternatively be raised with:

[Alternative Contact Name]

Email: [Alternative Contact Email]

5.4 A confidential reporting channel is also available at: [Reporting Hotline].

5.5 When raising a concern, workers should provide as much detail as possible, including: the nature of the concern; the dates, locations, and persons involved; the evidence or information on which the concern is based; and any steps already taken to address the concern informally.

5.6 Workers may be accompanied at any meeting held in connection with a concern raised under this policy by a trade union representative or a work colleague.

6. CONFIDENTIALITY

6.1 [Company Name] will treat all whistleblowing disclosures with strict confidentiality. The identity of a worker who raises a concern will not be disclosed without that worker's consent, except where [Company Name] is required to disclose it by law or where disclosure is necessary to enable the concern to be properly investigated.

6.2 Where disclosure of the worker's identity is necessary to enable investigation, the worker will be informed before disclosure is made, unless it is not practicable to do so.

6.3 Workers involved in the investigation of a whistleblowing concern — whether as investigators, witnesses, or subjects — are required to maintain confidentiality in relation to the matter throughout the investigation and thereafter.

6.4 Any breach of confidentiality by an employee in connection with a whistleblowing disclosure may itself constitute a disciplinary offence.

7. HOW CONCERNS WILL BE HANDLED

7.1 On receipt of a disclosure, the designated Whistleblowing Officer will acknowledge receipt [Investigation Timeline] of the concern being raised.

7.2 The designated Whistleblowing Officer will assess the concern and decide, in consultation with appropriate senior management, how it should be investigated. Depending on the nature of the concern, this may involve: an internal investigation conducted by the Whistleblowing Officer or another appropriate member of management; referral to an external investigator, solicitor, or auditor; referral to the police or a regulatory body; or a combination of the above.

7.3 The concern will be assessed promptly and, where appropriate, the worker who raised it will be kept informed of progress and the outcome of the investigation, to the extent permitted by considerations of confidentiality and the interests of any persons named in the disclosure.

7.4 Not every concern raised will result in a full investigation. Where preliminary enquiries show that the concern is unfounded, or where the matter is more appropriately addressed through another procedure, the worker will be informed of this decision and the reasons for it.

7.5 A record of all whistleblowing disclosures received and the steps taken in response will be maintained by the designated Whistleblowing Officer, in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

8. INVESTIGATION PROCESS

8.1 All investigations under this policy will be conducted promptly, objectively, and fairly. The person conducting the investigation will not be a person who is the subject of the concern or who has a conflict of interest in relation to the matter.

8.2 The investigator may interview the worker who raised the concern, the person or persons who are the subject of the concern, and any witnesses. All persons interviewed will be reminded of the requirement to maintain confidentiality.

8.3 Where a person is the subject of a whistleblowing investigation, they will be informed of the fact and the nature of the allegations at an appropriate stage of the investigation, unless doing so would prejudice the investigation.

8.4 The investigator will prepare a written report of findings and recommendations, which will be provided to the appropriate level of senior management or the Board. Where the investigation reveals evidence of wrongdoing, [Company Name] will take appropriate action, which may include disciplinary action, referral to law enforcement or a regulator, and remedial action to prevent recurrence.

8.5 The worker who raised the concern will be informed of the general outcome of the investigation, to the extent permitted by law and considerations of confidentiality.

9. PROTECTION FOR WORKERS WHO RAISE CONCERNS

9.1 [Company Name] is committed to ensuring that workers who raise concerns in good faith under this policy do not suffer any detriment as a result. This applies whether or not the concern is substantiated, provided it is raised honestly and in good faith.

9.2 Under s.47B of the Employment Rights Act 1996, a worker has the right not to be subjected to any detriment by their employer on the ground that they have made a protected disclosure. Detriment includes: dismissal; demotion; denial of promotion; unfair allocation of work; exclusion from training or opportunities; threats; harassment; bullying; or any other detrimental treatment.

9.3 Under s.103A of the Employment Rights Act 1996, dismissal of an employee is automatically unfair if the reason, or principal reason, for the dismissal is that the employee made a protected disclosure. There is no qualifying period of employment for such a claim, and compensation is not subject to the usual statutory cap.

9.4 Any worker who believes they have suffered a detriment as a result of raising a concern under this policy should report this immediately to the designated Whistleblowing Officer, the alternative contact, or, where appropriate, to senior management or the Board.

9.5 Any manager or employee who subjects a worker to detriment because that worker has raised a concern under this policy will be subject to disciplinary action, which may include dismissal for gross misconduct.

10. EXTERNAL DISCLOSURES

10.1 [Company Name] encourages workers to raise concerns internally in the first instance. However, workers are free to make a protected disclosure to a prescribed person or body under s.43F of the Employment Rights Act 1996 where they: reasonably believe that the concern falls within the remit of the prescribed person or body; and reasonably believe that the information they are disclosing is substantially true.

10.2 Workers may also make a protected disclosure directly to a regulatory or enforcement body under s.43G of the ERA 1996 in more limited circumstances — for example, where the worker reasonably believes that evidence relating to the wrongdoing will be concealed or destroyed if the disclosure is made internally, or where the concern has already been raised internally and the worker reasonably believes that no appropriate action has been taken.

10.3 Workers who are considering making a disclosure to a prescribed person or regulatory body are encouraged to seek advice in the first instance from the designated Whistleblowing Officer or from Protect (formerly Public Concern at Work), the UK's leading whistleblowing charity, which provides free and confidential advice to workers: www.protect-advice.org.uk.

11. PRESCRIBED PERSONS AND REGULATORY BODIES

11.1 Workers may make a protected disclosure directly to a prescribed person listed in the Prescribed Persons Order 2014 (SI 2014/2418). The relevant prescribed persons and regulatory bodies for the business of [Company Name] include:

[Prescribed Persons Reference]

11.2 A full list of prescribed persons is maintained by the Department for Business and Trade and is available at: www.gov.uk/government/publications/blowing-the-whistle-list-of-prescribed-people-and-bodies.

12. SUPPORT AVAILABLE TO WORKERS

12.1 [Company Name] recognises that raising a concern can be a stressful experience. Workers who raise concerns under this policy will be provided with appropriate support throughout the process.

12.2 The designated Whistleblowing Officer ([Officer Name]) is available to provide guidance on the process, answer questions about the policy, and provide updates on the progress of any investigation.

12.3 Workers may also seek independent confidential advice from the following external organisations:

Protect (formerly Public Concern at Work) — independent whistleblowing charity providing free and confidential legal advice: www.protect-advice.org.uk; advice line: 020 3117 2520.
ACAS (Advisory, Conciliation and Arbitration Service) — provides free and impartial advice on employment rights: www.acas.org.uk; helpline: 0300 123 1100.
Citizens Advice — provides free, independent, and confidential advice: www.citizensadvice.org.uk.

12.4 Where a worker who has raised a concern suffers financial loss as a result of having raised it, [Company Name] will consider whether indemnification of reasonable legal costs is appropriate, on a case-by-case basis.

13. RECORD KEEPING

13.1 [Company Name] will maintain a confidential register of all whistleblowing disclosures received, the steps taken to investigate each concern, the outcome of each investigation, and any action taken as a result.

13.2 All records relating to whistleblowing disclosures will be held securely and in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Access to the register will be restricted to the Whistleblowing Officer, senior management, and the Board as appropriate.

13.3 Records will be retained for a minimum of six years following the conclusion of each matter, in accordance with the Limitation Act 1980 and any applicable regulatory retention requirements.

13.4 Where [Company Name] is subject to reporting obligations to a prescribed person or regulator in connection with a whistleblowing disclosure, it will comply with such obligations within the timeframes required.

14. RESPONSIBILITIES

14.1 The Board of Directors / Senior Leadership is responsible for: approving and reviewing this policy; setting the appropriate 'tone from the top' with regard to whistleblowing and ethical conduct; ensuring that adequate resources are available to support the whistleblowing process; and receiving reports on whistleblowing disclosures and the actions taken in response.

14.2 The Designated Whistleblowing Officer ([Officer Name]) is responsible for: receiving and assessing whistleblowing disclosures; co-ordinating investigations; maintaining confidential records; communicating with workers who have raised concerns; and reporting to senior management and the Board on the operation of this policy.

14.3 All Managers are responsible for: creating a culture in which workers feel safe to raise concerns; being alert to potential disclosures; signposting workers to this policy; and not taking any action that could amount to detriment against a worker who has raised a concern.

14.4 All Workers are responsible for: familiarising themselves with this policy; raising genuine concerns promptly and in good faith; co-operating with any investigation of a concern they have raised or that relates to their conduct; and maintaining confidentiality in relation to any whistleblowing matter of which they become aware.

15. POLICY REVIEW

15.1 This Whistleblowing Policy will be reviewed by the policy owner at least annually, or sooner following any significant change in the law or regulatory guidance, any whistleblowing incident that highlights a deficiency in current procedures, or any material change in the nature or scale of [Company Name]'s business.

15.2 The policy owner responsible for maintaining and reviewing this policy is: [Policy Owner].

15.3 The next scheduled review date is: [Review Date].

15.4 Updates to this policy will be communicated to all workers. The updated policy will be made available on the company intranet or staff notice board.

16. POLICY APPROVAL

This Whistleblowing Policy has been reviewed and formally approved on [Approval Date] by [Approved By] on behalf of [Company Name].

This policy complies with the Employment Rights Act 1996 Part IVA (ss.43A-43L), the Public Interest Disclosure Act 1998, the Enterprise and Regulatory Reform Act 2013, and the Prescribed Persons Order 2014 (SI 2014/2418).

Designated Whistleblowing Officer: [Officer Name], [Officer Title] ([Officer Email] | [Officer Phone])

Alternative Contact: [Alternative Contact Name] ([Alternative Contact Email])

Policy Owner: [Policy Owner]

Approved By: [Approved By]

Effective Date: [Policy Date]

Next Review Date: [Review Date]

Authorised Signatory

[Approved By]

Signature

Date: ________________

Maintained by Vladislav Sergienko, Founder·Template last modified: 2026-06-23·Report an error

What Is a Whistleblowing Policy (UK)?

A Whistleblowing Policy in the United Kingdom sets out the standards, responsibilities, and procedures the organisation expects everyone to follow, and takes its legal force from the Companies Act 2006.

The purpose of a Whistleblowing Policy is to provide workers with a clear, accessible, and confidential process for raising concerns about wrongdoing, and to assure them that they will not suffer any detriment for doing so. The policy identifies the categories of concern that may be raised (known as qualifying disclosures), the persons to whom disclosures should be made, the process for investigating disclosures, and the statutory protections available to whistleblowers.

Under s.43B of the ERA 1996, a qualifying disclosure is a disclosure of information which, in the reasonable belief of the worker, is made in the public interest and tends to show that one or more specified types of wrongdoing has occurred, is occurring, or is likely to occur. These types of wrongdoing are: criminal offences, failure to comply with a legal obligation, miscarriages of justice, danger to the health or safety of any individual, damage to the environment, and the deliberate concealment of information relating to any of these matters.

The statutory protections for whistleblowers are among the strongest in UK employment law. Under s.47B of the ERA 1996, workers have the right not to be subjected to any detriment by their employer on the ground that they have made a protected disclosure. Under s.103A, an employee who is dismissed because they made a protected disclosure is automatically treated as having been unfairly dismissed, without any qualifying period of employment and with uncapped compensation. These protections apply to employees, workers, agency workers, and certain other categories of person defined in s.43K of the ERA 1996.

The legal framework governing the Whistleblowing Policy (UK) in United Kingdom draws on several key statutes and regulatory bodies. Under the Companies Act 2006, Companies House maintains the register of UK companies. Section 386 of the Companies Act 2006 sets accounting record obligations. The Competition and Markets Authority (CMA) enforces the Consumer Rights Act 2015. The Financial Conduct Authority (FCA) regulates financial services under the Financial Services and Markets Act 2000. The High Court of Justice has jurisdiction under the Senior Courts Act 1981. Parties executing a Whistleblowing Policy (UK) in United Kingdom should confirm the document reflects current law, including any amendments enacted since the original drafting date. The Companies Act 2006 sets the foundational requirements.

When Do You Need a Whistleblowing Policy (UK)?

A Whistleblowing Policy is needed by any organisation that employs or engages workers in England and Wales, regardless of its size, sector, or corporate structure. While the Employment Rights Act 1996 and the Public Interest Disclosure Act 1998 do not impose a general statutory obligation on all employers to maintain a written Whistleblowing Policy, the absence of such a policy carries significant legal, reputational, and operational risks.

In the financial services sector, the Financial Conduct Authority (FCA) has made whistleblowing arrangements mandatory. Under SYSC 18 of the FCA Handbook, firms authorised by the FCA must have appropriate internal procedures for handling disclosures by workers and must appoint a Senior Manager as the firm's whistleblowers' champion. NHS organisations are required under the NHS Standard Contract to have Freedom to Speak Up arrangements that include a named guardian and a written policy.

For private sector employers outside of regulated industries, ACAS strongly recommends having a written Whistleblowing Policy as part of good employment practice. The Equality and Human Rights Commission (EHRC) and the Chartered Institute of Personnel and Development (CIPD) also recommend that all employers adopt a clear whistleblowing procedure. A well-drafted policy serves multiple purposes: it provides a structured process for receiving and investigating concerns, reassures workers that they can raise issues without fear of retaliation, helps the organisation identify and address wrongdoing early, and demonstrates the organisation's commitment to transparency and accountability.

The policy is particularly important in organisations where the risk of wrongdoing is elevated, including those handling public funds, those operating in highly regulated sectors, those with complex supply chains, and those with a significant number of workers in safety-critical roles. It is also essential for organisations that are tendering for public contracts, as many procurement frameworks now require bidders to demonstrate that they have adequate whistleblowing arrangements.

What to Include in Your Whistleblowing Policy (UK)

A legally effective and operationally useful Whistleblowing Policy for England and Wales should contain several key elements, each grounded in the statutory framework of the Employment Rights Act 1996 Part IVA and supporting legislation.

A clear statement of purpose that explains what whistleblowing is, why the organisation values it, and the commitment of the organisation to protecting workers who raise concerns in good faith. The statement should make explicit that the policy covers all categories of qualifying disclosure under s.43B of the ERA 1996 and that it applies to employees, workers, contractors, agency workers, and other relevant persons.

A definition of qualifying disclosures that accurately reflects the six categories of wrongdoing set out in s.43B(1) of the ERA 1996: criminal offences, failure to comply with legal obligations, miscarriages of justice, danger to health and safety, environmental damage, and deliberate concealment of any of the foregoing. The policy should make clear that the worker needs only a reasonable belief, not proof, that the wrongdoing has occurred or is likely to occur.

Detailed internal reporting procedures that identify a designated whistleblowing officer by name, title, and contact details, together with an alternative contact for situations where the designated officer is the subject of the concern or is unavailable. The policy should also specify whether a confidential reporting hotline or anonymous reporting channel is available.

Information about external reporting options, including the right to make a protected disclosure to a prescribed person under s.43F of the ERA 1996 and the Prescribed Persons Order 2014. The policy should list the prescribed persons most relevant to the organisation's sector and activities and provide a reference to the full list maintained by the Department for Business and Trade.

A clear statement of the protections available to whistleblowers, including the right not to be subjected to detriment under s.47B and the right not to be unfairly dismissed under s.103A of the ERA 1996. The policy should define what constitutes detriment and should state that any person who subjects a whistleblower to retaliation will themselves be subject to disciplinary action.

A detailed investigation procedure that sets out the steps the organisation will take upon receiving a disclosure, including acknowledgment timescales, appointment of an investigator, the right of the whistleblower to be accompanied at meetings, communication with the whistleblower during and after the investigation, and the actions the organisation may take based on the findings.

Confidentiality protections that explain how the organisation will protect the identity of the whistleblower and the circumstances in which disclosure of their identity may be necessary. A section on anonymous disclosures, if the organisation accepts them, should address the limitations of anonymous reporting.

A policy on false or malicious allegations that distinguishes clearly between genuine concerns that are not ultimately substantiated (which are protected) and deliberately false or malicious allegations (which may result in disciplinary action). Record-keeping obligations, a review schedule, and approval details complete the essential elements. The forms-legal.com Whistleblowing Policy (UK) template covers the mandatory elements under Companies Act 2006.

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Forms Legal. (2026). Whistleblowing Policy (UK) (United Kingdom) [Legal document template]. Forms Legal. https://forms-legal.com/uk/business/policies/whistleblowing-policy-uk

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@misc{formslegal-whistleblowing-policy-uk,
  author       = {{Forms Legal}},
  title        = {Whistleblowing Policy (UK) (United Kingdom)},
  year         = {2026},
  howpublished = {\url{https://forms-legal.com/uk/business/policies/whistleblowing-policy-uk}},
  note         = {Free legal document template. Based on Companies Act 2006}
}

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Frequently Asked Questions

Based on Companies Act 2006 — Template last modified June 2026Verify the source →

This template is provided for informational purposes only and does not constitute legal advice. Laws vary by jurisdiction and change over time. Consult a qualified attorney for advice specific to your situation.Full disclaimer

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Whistleblowing Policy (UK)

[Company Name]

What Is a Whistleblowing Policy (UK)?

When Do You Need a Whistleblowing Policy (UK)?

What to Include in Your Whistleblowing Policy (UK)

Cite this page

Also available for these jurisdictions:

Frequently Asked Questions

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