Step 3 : Policies

One of the critical elements in embedding SpeakUp is capturing the process for raising concerns in your policies. This is typically included in the Code of Conduct and the SpeakUp Policy (also known as the ‘whistleblowing policy’). For some organisations, dedicated supplier codes are also in place for external parties. 

Essential Documents

• SpeakUp Policy: Guides employees and external parties on how and where to raise concerns, including anonymous reporting and what happens with their reports.
• Code of Conduct: Defines the organisation's values. Some organisations integrate the SpeakUp policy within this document.
• Supplier Code: Provides suppliers with instructions on raising concerns and the available channels.

Additional Documents

• One page SpeakUp policy
  
  Every organisation is unique, defined by its people and culture. That's why it's essential to think outside the box when developing your SpeakUp Policy. One-Page SpeakUp Policy is a great idea for that! A visually engaging document that combines clarity and simplicity, making the essential points of your SpeakUp Programme easily accessible and understandable without much legal jargon.

Figure : Example of one-page SpeakUp policy

14 Principles for Writing Your SpeakUp Policy

1. The Mindset Challenge
   
   Organisations aim to achieve early transparency through speaking up, alongside compliance with whistleblowing law. These objectives can conflict, particularly when strict legal compliance complicates the process. Prioritise what's right for your employees over rigid legal terminologies and procedures. 
   
   
2. The Governance Check
   
   Establish a clear workflow and governance structure. Determine who your reporting personas are, who will triage reports, who will conduct investigations (in-house or externally), and understand the message flow. 
   
   

3. The Right Positioning of SpeakUp

   Foster an open culture where your colleagues feel comfortable raising concerns. Position SpeakUp as a last resort, available when direct communication (to managers, HR, or compliance) is not possible. 
   
   

4. Tone at the Top

   Begin your SpeakUp policy with an introductory note from the CEO. This demonstrates top-level endorsement and the seriousness of the topic.
   
   

5. Use Easy and Simple Language

   Most people don’t speak ‘law’. If people fear for disciplinary measures or retaliation, they will not report at all. Choose positive wording and tone of voice that fits your company culture. Avoid legal jargon like ‘whistleblowing’. Use more positive, clear language that fits your company culture to lower the barriers for raising concerns.
   
   

6. Compliance and Approvals

   Ensure your policy is compliant with relevant laws and protects the rights of all parties involved:

   • Rights of the reporter
   • Rights of the accused
   • Privacy Law
   • Labour Law
   • EU Whistleblowing Protection Law
   • Anti-Corruption Law
   • Consent

    

7. How to Use the SpeakUp Line?

   Provide clear instructions on using the SpeakUp system, possibly with visuals. Address common questions reporters might have, such as:

   • What happens to my personal data?
   • What happens to the accused person?
   • Will all reports be investigated?

8. Inviting and Reassuring the Messenger

   Ensure reporters know it is safe to raise concerns and that they can report anonymously if needed.
   
   

9. Alignment with the Code of Conduct and Scope

   Clarify what should be reported, using specific examples. Align these with the values expressed in your Code of Conduct.
   
   

10. Providing Transparency

    Outline what reporters can expect: response timelines, who will receive their message, and the follow-up process. Ensure transparent handling of reports by a dedicated team.
    
    

11. Local Deviations

    Acknowledge that certain laws or codes may require specific arrangements. Consider adding annexes for local deviations while keeping the system low barrier.
    
    

12. Format of the Internal Reporting Procedure

    There is no fixed format for a SpeakUp policy. It can be named variously (e.g., Misconduct Reporting Procedure, Raising Concerns Policy). Ensure it meets your objectives and legal requirements.

13. Roll Out and communication campaign 

    Work with your communications team for an effective rollout. Refer to our Client Catalogue for example. 
    
    

14. Clear transparency in Handling Cases 

    Communicate clearly when reporters can expect a reply and detail the follow-up procedure. Be transparent to show that every report is handled seriously by a dedicated team.

By adhering to these principles, you will develop a SpeakUp Policy that encourages transparency, supports ethical behaviour, and ensures compliance with relevant regulations.