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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 comparatively list 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 establishing a reporting channel, provide whistleblowers with clear instructions on addressing their reports. 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. It will be done within the organization in order to ensure their confidentiality and integrity.
When internal letterboxes are used as a reporting channel, explicitly 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.
The EU Directive stipulates that channels for receiving the reports need to be designed. Identically established and operated in a secure manner that ensures that the confidentiality of the whistleblower’s identity. Most importantly any third party mentioned in the report is protected, and prevents access thereto by non-authorised staff members.
However 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 will 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. Similarly, provisions apply also when transcripts of reports received through recorded telephone lines or other recorded voice messaging systems are prepared. Whether when a conversation with a whistleblower via unrecorded telephone line or other unrecorded voice messaging system is documented with minutes.
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