Whistleblowing Management Compliance Update: January 2021

As organisations in many countries adjust to new corporate whistleblower regulations and laws, many wonder if there will ever be a global standard for the operation of whistleblowing programs….The good news is that soon there will be!

Specifically, the International Organization for Standardization/ISO has a working group for this project and their draft guidance has been approved: ISO 37002 Whistleblowing management systems – Guidelines.  The current draft (known as a DIS) is generally 95% accurate to what is expected to be published as the final version in June 2021. To keep track of the release of the ISO standard, bookmark this link:

Your Call clients will be proud to learn the pending ISO standards revolve around similar foundation principles currently instilled within our service including trust, impartiality, and protection. ISO 37002 will provide guidelines for implementing, managing, evaluating, maintaining and improving a robust and effective whistleblowing management system.  Importantly, this standard will apply across all sectors and business types (including non-profits).  Organizations can use ISO 37002 as stand-alone guidance or pair it with other management system standards related to ethics, quality, risk, and whistleblowing.

Notably, the DIS 37002 contains both reactive and proactive elements related to whistleblowing.  This is because the whistleblowing process is recognised as a serious, emotional, and complex endeavour that must be managed in an ethical and rigorous manner. Training components must include not only comprehension of the whistleblower management system, but importantly, training regarding codes of conduct/ethics as these can help instill values that promote ethical behavior (Section 7.3.2 k).  Additionally, the standard provides definitions of terms (Section 3) such as “whistleblower” and “whistleblowing” which can be helpful in countries where no legislated definition exists.  Numerous specific examples of inappropriate behaviour are also included in their definition of “wrongdoing.”

ISO takes a key step with their standard and reminds organizations that it’s not enough to have a whistleblower management system ‘on paper’ — a thick binder of documents on a shelf in the Compliance Department, or a glitzy webpage on the corporate intranet.  Specifically, whistleblowing management systems must be adequately resourced (Section 7.1).  These resources include financial, computing, and human capital/people and their special skills (legal, investigative, training, etc.)  This means organizations must be able to truly operationalize their whistleblowing management system—it cannot be a cosmetic endeavor that lacks skilled substance.

Another welcome inclusion in the ISO standard is “note 4” alongside the definition of “detrimental conduct.”  This content provides protection for “any person involved in a whistleblowing process”.  Intermediaries in the whistleblowing process such as Eligible Recipients, Integrity Officers, Integrity Coaches/Champions, and Investigators (as relevant stakeholders) are now given explicit protection from abuse such as ‘shooting the messenger’ behavior (Bramstedt 2020,  These roles are vital and ISO is applauded to have recognized the potential for harm beyond the whistleblower.

When investigations are completed and the subject of the investigation is cleared [no wrongdoing] there can be the tendency to think “all is well”, “hooray, it’s over”, but these thoughts are simplistic and underestimate the weight that whistleblowing cases cast on the accused.  As an analogy, when someone has been swimming in a swamp, do they simply emerge walking tall and clean? Mostly likely they have a taste of sulphur in their mouth, their skin smells like rotten eggs, and their muscles ache from the viscous trudging. The new ISO standard (Section 8.4.4 e) calls for protecting the subject of a whistleblowing report after the case has concluded and the subject was cleared of wrongdoing.  Such protections could include reputational and financial remediation, among other things.  Specifying remediation as a standard will be welcomed as the swamp situation can be costly with post-case assistance needed so that subjects can rejuvenate.

As trusted advisors by hundreds of organisations, Your Call and Clarity Workplace Solutions are ready for this new ISO standard to launch from their Switzerland headquarters.  We offer an ASIC and ISO-compliant whistleblower management system, as well as related advisory and training services ensuring you operate a best-practice and compliant program. Video:


Prof. Katrina Bramstedt