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Establishing an Internal Reporting Office

Are you setting up an internal reporting office? This page helps you with the setup of the internal reporting office.

Whistleblowing Directive Checklist​

To establish an internal reporting office, you need to

  • appoint responsible persons,
  • provide these persons with enough time and resources so that they can
    • define the process for reports,
    • possibly prepare a whistleblowing policy and a privacy policy,
    • possibly introduce a whistleblower portal,
    • possibly inform the works council and data protection officers and
    • support the internal introduction of the reporting office (among others with a notice).

Tips for Establishing an Internal Reporting Office​

Take a professional expertise training.

Define who is part of your internal reporting office.

Define the working methods and processes for handling incoming reports. The case management of a whistleblower portal software will support you in this.

Ensure that your work within the reporting office is independent.

Be aware that in the case of media coverage or foreseeable legal consequences, investigations should be conducted by, for example, a law firm.

Ongoing Information​

Inform employees immediately after establishment and then continuously about the internal reporting office. Make sure to repeatedly emphasize the following aspects:

  • Why and for what purpose the reporting office exists
  • "We acknowledge receipt of reports within seven days."
  • "We respond to reports with results and follow-up actions within three months."
  • "X, Y, and Z work in the reporting office."
  • "Your reports are confidential according to § 8 HinSchG."
  • "We are operating fully independent."
  • Strongly recommended: "We also accept anonymous reports."

Use notices, intranet or wiki, Slack reminders, e-learnings, and all other means available to you.

Staffing the Internal Reporting Office​

It is recommended that you staff the internal reporting office with at least two people to ensure deadlines are met even during vacations and absences due to illness.

If you appoint an internal person to the reporting office, you must ensure that

  • independence (from other persons, departments, etc.) is maintained,
  • there are no potential conflicts of interest, and
  • this person has the necessary expertise.

Best practice is to appoint an ombudsperson for certain cases (representation rule for conflicts of interest). GlobaLeaks, for example, allows the selection of recipients in individual channels.

It is also recommended to have at least one woman and one man in the internal reporting office. This way, cases of discrimination, etc., can be adequately addressed.

Reasons for External Ombudspersons​

Staffing with external ombudspersons prevents all possible problems associated with staffing by internal employees.

In general, external persons are completely independent and have no conflicts of interest when handling reports.

Additionally, external ombudspersons are specialized and usually have more expertise and know-how in dealing with reported misconduct.

External ombudspersons can also create a whistleblowing policy, data protection notices, etc., for you.

Good to Know

No ombudsperson at hand? Please contact Support.

Whistleblower Protection Act Notice Template​

Here you can download a template for the announcement of the internal reporting office in your organization:

The text is as follows:

REPORT MISCONDUCT TO THE INTERNAL REPORTING OFFICE

Dear Colleagues,

you can now report the misconduct of other employees to our internal reporting office. You can submit reports through our website.

Our website:
https://hinweise.example.com

Completely anonymous with the Tor Browser:
abcdef.onion

You can submit reports anonymously. Your reports are confidential (according to § 8 HinSchG) and can only be viewed by our team. We investigate reports independently within the team of the internal reporting office. We confirm receipt of reports within seven days. We respond to reports with results and follow-up actions within three months.

Your Internal Reporting Office Team

Maria Musterfrau
Max Mustermann