Whistleblower Compliance Checklist

Introduction

This comprehensive checklist helps organizations establish and maintain effective whistleblower protection programs. Use this guide to assess your current compliance status and identify areas for improvement.

How to Use This Checklist:

Review each section thoroughly
Check off items as you complete them
Note any gaps or areas needing attention
Set priorities based on risk assessment
Document completion dates and responsible parties

Policy and Documentation

Develop and maintain a comprehensive whistleblower policy
Include clear definitions of protected disclosures
Document reporting procedures and channels
Establish confidentiality protocols
Create anti-retaliation provisions
Define investigation procedures
Document record retention policies
Create policy review schedule

Legal Compliance

Review applicable whistleblower protection laws
Ensure compliance with Sarbanes-Oxley Act (SOX)
Implement Dodd-Frank Act requirements
Address state-specific whistleblower laws
Consider international regulations if applicable
Maintain documentation of compliance efforts
Review and update legal requirements annually
Document legal consultation records

Reporting Infrastructure

Establish multiple reporting channels
Implement secure online reporting system
Set up confidential hotline
Create secure document storage system
Develop case management procedures
Establish escalation protocols
Implement reporting analytics
Create backup reporting systems

Training and Awareness

Conduct regular employee training sessions
Train managers on handling reports
Provide investigator training
Create awareness materials
Document all training activities
Schedule annual refresher courses
Develop role-specific training modules
Create training effectiveness metrics

Response and Investigation

Establish investigation team
Create investigation protocols
Develop evidence collection procedures
Set up witness interview process
Create documentation templates
Establish reporting timelines
Define escalation procedures
Implement investigation tracking system

Monitoring and Review

Track report statistics
Monitor response times
Review investigation outcomes
Conduct periodic policy reviews
Assess program effectiveness
Implement continuous improvements
Develop performance metrics
Create benchmarking reports

Documentation and Record-Keeping

Maintain report logs
Document investigation findings
Track corrective actions
Store supporting evidence
Create audit trails
Establish retention policies
Implement document version control
Create backup procedures

Priority Levels:

High Priority: Critical for compliance and risk management
Medium Priority: Important for program effectiveness
Low Priority: Enhances program quality

Note: This checklist is a general guide. Consult with legal counsel to ensure compliance with all applicable laws and regulations.