Policies and Procedure
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By Hilary Davies, MES

In Canada, whistleblowers often only come to public attention when the reporting is external and a sensational story hits the news. At this point, the reputational damage to an organization is already done and the opportunity to mitigate the effects may have disappeared.

External reporting also frequently involves illegal or unethical activity that may have been occurring for a long period of time. The reporting of malfeasance within an organization may be external because the organization does not have an effective internal reporting mechanism.

In February 2016, CSA Group published its first guideline for whistleblowing systems. The guideline is designed to help organizations set up an internal ethical reporting program that encourages reporting of wrongdoing within the organization itself. Some readers may be asking – why would an organization want to encourage whistleblowing?

“Whistleblowing,” which is the act of reporting suspected wrongdoing, mismanagement and unethical conduct in an organization, is one of the most effective methods for identifying activities that could potentially cause harm to an organization, the public interest or the health and safety of the environment. The information gained from whistleblowing activities can be invaluable to organizations seeking to prevent the damages that could result from these activities. For these and other reasons, government bodies, corporations and non-profit associations are looking for ways to proactively encourage a “speak-up” culture that enables their employees to voice any concerns, according to the International Handbook on Whistleblowing Research, which was published in 2014.


Having an effective ethical reporting system that encourages employees or clients to report wrongdoing is an important component of overall corporate governance.

Having an effective ethical reporting system that encourages employees or clients to report wrongdoing is an important component of overall corporate governance. International research, reported in the Journal of Financial Crime, has shown that whistleblowing activities are one of the best mechanisms for organizations to detect internal wrongdoing and improve overall organizational effectiveness. A workplace culture that promotes “speaking up” and reporting of wrongdoing can empower employees to take an active role in their workplace, improve shareholder confidence and help create an environment where employees feel free to contribute to the advancement of the organization.

One of the most important components of a successful system is that the employees believe in its efficacy. Employees are more likely to pass along information if they have confidence that by reporting wrongdoing, their concerns will be taken seriously and their actions will make a positive change. This belief begins at the top – the executives must actively support the program, promote and display ethical behaviour and ensure there is awareness among employees of how the program works, the procedures involved and the protections put in place for any whistleblower.

Another concern for many whistleblowers is the potential for reprisal. As a result, organizations must help ensure that retaliation does not take place and that the system itself is evaluated periodically to give insight into its effectiveness to avoid any potential issues. Offering a confidential method of reporting often alleviates these concerns. It is also important to review each case and help ensure that any negative behaviour toward a whistleblower is addressed immediately.

Whistleblowing Systems – A Guide was developed to help organizations establish and manage an effective mechanism for whistleblowing activities. The guideline provides a background on existing Canadian laws and codes related to whistleblowing as well as a summary of the key performance benefits associated with a whistleblowing system. In order to help organizations develop internal systems specific to their operations, the guideline highlights key planning considerations and identifies the target outcomes of a successful system. It also addresses the most critical issues in developing an effective system, including the challenge of protecting whistleblowers from reprisals that punish and silence them, and discourage others from speaking out.

Although the elements of a whistleblowing system may vary depending on organization size and business, the guideline defines the common critical elements and provides recommendations for an appropriate implementation approach. Whistleblowing systems can become a valuable part of a comprehensive occupational health and safety management strategy that promotes accountability and gives workers a voice and influence within their workplace.

Ultimately, an effective internal reporting system can help both the organization and its employees. It allows the organization to proactively address any behaviour that is contrary to the policies and procedures of the organization, and gives employees confidence that their concerns will be appropriately addressed. 

Hilary Davies, MES is project manager, Environment and Climate Change at CSA Group.

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