Whistleblowing Policy (Public Interest Disclosure) Template for UK Businesses
A whistleblowing policy sets out how employees and workers can raise concerns about wrongdoing within the organisation and the protections available to them. The Public Interest Disclosure Act 1998 (PIDA), which inserted provisions into the Employment Rights Act 1996, protects whistleblowers from detriment and dismissal when they make qualifying disclosures about specified categories of wrongdoing. Having a clear policy encourages internal reporting and helps organisations identify and address problems before they become crises.
Who Needs This Policy?
Every UK employer should have a whistleblowing policy. While PIDA does not mandate a written policy, the FCA requires regulated firms to have one, and it is strongly recommended by the Department for Business and Trade for all employers. The protections apply to employees, workers, agency workers, and certain other categories — not just employees. Organisations that handle public funds, operate in regulated sectors, or manage significant health and safety risks should treat this as essential.
What's Covered
This whistleblowing policy (public interest disclosure) template covers 12 key sections:
Purpose
This policy encourages employees and workers to report concerns about wrongdoing, malpractice, or dangers within [your d...
Scope
This policy applies to all employees, workers, agency workers, contractors, trainees, home workers, and former employees...
Policy Statement
[your details] takes all concerns about wrongdoing seriously and will investigate them thoroughly. We are committed to: ...
How to Raise a Concern
Workers who wish to raise a concern should normally report it to their line manager in the first instance. If this is no...
Investigation Process
Once a concern is raised, [your details] will: 1. of the concern within 5 working days 2. to determine whether it fal...
Protection from Detriment
Workers who make a qualifying disclosure in the public interest are protected under the Employment Rights Act 1996 from:...
Confidentiality
[your details] will maintain the confidentiality of the whistleblower's identity as far as possible. The whistleblower's...
External Disclosures
[your details] encourages workers to raise concerns internally in the first instance. However, workers have the legal ri...
ERA 2025: Sexual Harassment as Qualifying Disclosure
From April 2026, the Employment Rights Act 2025 adds sexual harassment to the list of matters that constitute a qualifyi...
Roles and Responsibilities
is responsible for: - Ensuring this policy is communicated to all workers - Ensuring concerns are investigated promptly...
Related Policies
This policy should be read alongside the following policies: - Anti-Bribery Policy - Data Protection Policy - Anti-Hara...
Review
This policy will be reviewed annually, or sooner if there are changes to whistleblowing legislation, prescribed persons ...
Legal Framework
This policy template is grounded in the following UK legislation and guidance:
- Public Interest Disclosure Act 1998 (inserting Part IVA into the Employment Rights Act 1996, ss.43A-43L)
- Employment Rights Act 1996, ss.47B, 103A (protection from detriment and dismissal)
- Employment Rights Act 2025 (sexual harassment as qualifying disclosure from April 2026)
- Enterprise and Regulatory Reform Act 2013 (public interest test)
- Prescribed Persons (Reports on Disclosures of Information) Regulations 2017 (SI 2017/507)
How Complaiance Helps
Our whistleblowing policy (public interest disclosure) goes beyond a generic template:
- Covers all six categories of qualifying disclosure under section 43B of the Employment Rights Act 1996
- Clear reporting channels with named contacts and external escalation routes (regulators, prescribed persons)
- Robust protection provisions against detriment under section 47B and unfair dismissal under section 103A
- Confidentiality commitments and guidance on the distinction between confidential and anonymous disclosures
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Get Started FreeFrequently Asked Questions
What is a qualifying disclosure under UK whistleblowing law?
Under section 43B of the Employment Rights Act 1996, a qualifying disclosure is one that, in the reasonable belief of the worker making it, tends to show one or more of: a criminal offence, a failure to comply with a legal obligation, a miscarriage of justice, a danger to health and safety, damage to the environment, or the deliberate concealment of any of these. The disclosure must be made in the public interest.
Can a whistleblower be dismissed?
Dismissing an employee because they made a protected disclosure is automatically unfair under section 103A of the Employment Rights Act 1996 — no qualifying period of service is needed. Workers (who cannot claim unfair dismissal) are protected from detriment under section 47B. Compensation for whistleblowing dismissal is uncapped, unlike ordinary unfair dismissal which is subject to a statutory cap.
Does a whistleblowing disclosure have to be in the public interest?
Yes. Since the Enterprise and Regulatory Reform Act 2013 amended PIDA, a disclosure must be made in the public interest to qualify for protection. A purely personal grievance (e.g., a complaint about your own contract terms) is unlikely to qualify. However, the 'public interest' test is broad — a disclosure about wrongdoing affecting a group of employees, customers, or the public will generally qualify.