Many of you may recall that back in 2013 we launched our Listen Up! campaign. At the time this was a novel perspective. This was because debate and discussion was far more focussed on the idea of encouraging speaking up due to a dawning recognition that encouraging staff to disclose concerns about risk and wrongdoing in the workplace through whistleblowing – or “speak up” - arrangements was an important risk management tool for businesses.

In the six or so years since our original launch of Listen Up! the whistleblowing landscape has evolved. In 2019 having “speak up” or other reporting channels in place is, at least for many large businesses in the UK, now “the norm”. Having tracked developments and trends over the last six years we think it is timely to refocus on our Listen Up! campaign.

In 2014 we conducted research into FTSE100 companies looking at the extent to which large organisations had publicly visible reporting or whistleblowing channels.

In late 2018 we refreshed our research, which I am pleased to present in this blog post. (Whistleblowing/Reporting: FTSE 100).

The results of our research show some very interesting trends in the management of whistleblowing within FTSE100 companies and the extent to which large organisations make reporting channels available to their workforce.

In terms of key findings, some interesting points emerge: in 2014 our research found that, based on publicly available sources, 71% of FTSE100 companies made reference to having some form of reporting channel available. In late 2018 we found that all of the FTSE100 companies at that time made some form of reference in publicly available material (however cursory) to the existence of a reporting channel for concerns. Moreover, as at late 2018, 71% of FTSE100 companies made details of their policy or arrangements publicly available. Because we were able to find more publicly available information in 2018 we can identify some trends. For example, we can see that it is typical for reporting arrangements in 2018 to offer a range of methods of escalating concerns, with an externally managed independent dedicated phoneline being the most frequently referred to method.

Through a series of future blogs I will be focussing on the findings of our 2018 research and will also be looking at what can be drawn from similar research that we also undertook in late 2018 into the visibility of reporting arrangements at top European and Asian companies.

Whilst having “speak up” or whistleblowing arrangements in place, at least for large UK businesses, is now increasingly the norm, there are very compelling reasons for re-focussing on Listen Up! in 2019. As a result of speak up arrangements becoming more prevalent and visible since 2013 far more individuals are raising issues through such arrangements which inevitably stress tests the efficacy of existing processes and can flag up systemic weaknesses and expose organisations to legal, regulatory and reputational risk.      

This is against a backdrop in which UK businesses are becoming more concerned with demonstrating ethical leadership and a healthy culture, in part due to a number of a high profile issues such as #MeToo which have led to far greater public, governmental and regulatory scrutiny of culture and what a healthy culture looks like and how organisations demonstrate it. For example, this focus on culture and key stakeholder engagement has culminated in various new aspects within the 2018 Corporate Governance Code relating to the importance of hearing diverse voices at board level including via effective whistleblowing arrangements. In the financial services sector the FCA will be focussing on a culture agenda in 2019 within which having effective whistleblowing or “speak up” arrangements is seen as a central pillar when creating a culture of “psychological safety” for staff.

Stay tuned for further posts about Listen Up! where I will be considering the topic from a number of perspectives, tracking developments and trends and sharing the findings of our research.