What to Do When a Report Comes In?
Typically, very few cases are reported each year. When a report comes in, it is always a special situation. This rough process serves as a quick guide:
-
Send an acknowledgment of receipt within the legal deadline of 7 days:
Dear Whistleblower,
We have received your report from {Date} and are beginning to process it.
Best regards,
{First Name Last Name} -
Check whether
- this report is relevant to your work in the internal reporting office AND
- this matter could be true.
-
Plan further investigations and conduct these investigations by involving only the necessary persons.
-
Determine follow-up actions. These could include, for example:
- Outsourcing the internal investigation to a law firm.
- Filing a report with the public prosecutor's office.
- Reporting the matter to the HR department for potential disciplinary actions by them.
- Terminating the investigation (due to lack of evidence).
- Other measures
-
Inform the whistleblower within 3 months of the actions taken and further planned follow-up actions. Justify these actions. You may not be able to discuss personal consequences for accused persons due to data protection reasons.
-
Maintain legally sound documentation for at least 3 years.
Documents from your professional expertise training should provide further, detailed information.
This list does not claim to be exhaustive.