Whistleblowing For Board Members

As of December 17 2021, all companies with 250 or more employees need to implement a whistleblowing system compliant with GDPR and their national EU Whistleblowing Protection Directive. The board members share a responsibility to oversee the organization’s arrangements for whistleblowing and ensure that the procedures lead to positive results and a healthy safety valve.

Whistleblowing for board members is a list of recommendations made by the professionals at NorthWhistle. These recommendations will help you streamline the whistleblowing procedures and the system itself within your organization.

How To Optimize Oversight Efficiency

  • Ensure that the employees have faith and trust in your organization’s internal policies, and ensure that there is no retaliation made against whistleblowers. Internal whistleblowing is vital to being a healthy organization. Take all whistleblowing reports seriously and treat them correctly, as it can damage your brand’s reputation and finance if you do not. The entity of your business will benefit from a whistleblowing service.
  • Implement more than one channel to use for reporting wrongdoings and misconducts.
  • Assign the internal audit committee to participate in forming the whistleblower process, or at the very least, evaluate it. The audit committee is more often than not very experienced within multiple divisions of the organization.
  • Ensure that your whistleblowing program evolves as you do because the regulatory requirements are constantly changing as well. If the people responsible for your whistleblowing program last year were reassigned to other positions or let go, you need to update the program with the new people as well. With NorthWhistle’s whistleblowing service you can feel secure regarding always using the latest updates. 


The directors of the board are responsible for establishing the policy that is the foundation for the system. The board members are responsible for ensuring that the organization’s whistleblowing program leads to positive results.

  • Obligations
    • Assure that the system is confidential in all aspects, whether it’s sending a report by text message, e-mail, voice recording, and more. Currently, there are plenty of cheap yet innovative whistleblowing service plans & packages available.
    • Ensure that it meets the legal requirements set by the GDPR and the EU Whistleblower Directive in your nation. 
    • Ensure that the whistleblower is not receptive to retaliation or detriment by anyone within the organization. They are constantly under protection by European law. 
  • Activities
    • Test the different channels for regularly reporting to ensure its safety and efficiency.
    • Metrics of the system’s performance needs evaluation by the board level. 
    • Encourage whistleblowing to raise issues before they eventually lead to damaging your organization’s reputation. 

50 vs. 250, What’s The Difference?

First, it’s essential to address that the EU Whistleblower law requires organizations with 250 or more employees to implement a whistleblower policy and system by 17th December 2021 and organizations with 50 or more employees by 17th December 2023. Even though this is the general deadline for the implementation, some countries are different from others, and you need to align with the rules in your organization’s location. 

The difference between the two, other than above, is that you need to assign more handlers responsible for overseeing incoming reports, following up, investigating, etc., in a company with 250 or more. While 1 or 2 people may be enough to handle a business with sub 50 employees, one with 250+ may require 10 handlers. 

It’s a lot harder to maintain control over your employees when you exceed 50 employees. If you don’t already have an HR manager, this is the time to get one. Hiring a full-time legal representative or a business lawyer is crucial since internal and external risks significantly increase with more employees.


It’s crucial to track and measure the monthly number of reports received, the category of wrongdoing, and the validation processes. Find answers to how the investigation of incidents is going, both completed and those currently in progress. How do you follow them through? 

Benchmark your organization’s whistleblowing program against your industry’s best practices, compare with your industry peers to ensure that you identify and solve potential gaps.


Being a board member of your organization, it’s of utter interest for you, your peers, and everyone who is inferior that you shoulder your responsibilities and are continuously streamlining the whistleblowing program within your organization.

Why? When a company is growing, everything within it increases – whether it’s more employees, more software, more extensive sales, more clients, or customers, which means that your risks are also increasing. All of this will also increase the amount of possible misconduct within your business. 

Ensure you are aware of the critical dates within your country and that your organization meets the requirements.