Whistleblower Compliance Checklist

How to use this checklist

This is an assessment tool, not a compliance certificate: work through each area, mark what is already in place, and treat the gaps as a backlog ordered by the priority marks.

Review each section thoroughly
Including the areas you believe are already covered — “we have a policy” and “people know where it is” are different claims.
Check items off as you complete them
Ticks are saved in this browser only. Nothing is sent anywhere, and nothing is shared.
Note the gaps and who owns them
Print the page once you are done and take the unticked rows into your next review.

Priorities are a starting point, not a legal ranking — reorder them against your own risk assessment.

High — critical for compliance and risk
Medium — important for the programme to work
Low — enhances programme quality

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Policy and documentation

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

Legal compliance

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

Reporting infrastructure

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

Training and awareness

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

Response and investigation

Establish an investigation team Priority: High
Create investigation protocols Priority: High
Develop evidence collection procedures Priority: High
Set up a witness interview process Priority: Medium
Create documentation templates Priority: Medium
Establish reporting timelines Priority: High
Define escalation procedures Priority: Medium
Implement an investigation tracking system Priority: Low

Monitoring and review

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

Documentation and record-keeping

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

Before you rely on this

This checklist is a general guide

It is not legal advice and it is not exhaustive. Requirements vary by jurisdiction, sector and organization size. Consult legal counsel to confirm compliance with all applicable laws and regulations.