Comsure defines whistleblowing as the reporting by staff or third parties to the company, investors or authorities, any knowledge or credible suspicion of attempted or actual misconduct, including corruption.

WHY IS WHISTLEBLOWING IMPORTANT FOR COMPANIES AND INVESTORS?

Whistleblowing is an essential tool to strengthen accountability and combat corruption.

A Well-designed and well-implemented whistleblowing system can encourage people to report corrupt practices, which in turn strengthens a company’s oversight systems and helps reduce corruption in the long term.

Regulated firms should ensure that investee companies have strong whistleblowing systems in place, including the elements below as a minimum.

Companies should have robust whistleblowing policies and procedures, evidenced by:

1. A clear statement of the policy:
   1. Firms should ensure there is a clear statement that the company is open to whistleblower reports from staff and third parties and that it will investigate and, where appropriate, act upon such reports.
   2. The policy should guarantee that employees are protected from any adverse consequences for reporting corrupt practices.
2. Systematic communication of the policy and procedures:
   1. Firms should ensure the whistleblowing policy and procedures are communicated to all employees (e.g. via the staff handbook and in regular training).
3. The appointment of a member of senior management responsible for overseeing implementation of the policy and procedure:
   1. Firms should ensure that a member of the senior management of each company has been assigned responsibility for overseeing and reporting to the Board on the implementation of the whistleblowing policy.
4. Public statement of the whistleblower policy and procedures:
   1. Firms should publishes a clear statement of the whistleblowing policy on their website.
5. Confirmation of annual reports and accounts:
   1. Companies should include a clear statement of annual accounts and reports that the Board is satisfied that the whistleblowing policy has been effectively implemented.