U.K. Commission Says “No” to Bounties for Whistleblowers

by NAVEX Global

The United Kingdom’s Parliament has been considering offering whistleblower bounties similar to those offered under the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act. A commission formed by the Bank of England and the UK Financial Conduct Authority spent time with U.S. regulators to investigate the benefits and the drawbacks of this type of legislation. The commission’s recommendation back to Parliament? A resounding no!

Employees to Bounty Hunters?

Dodd-Frank’s whistleblower bounty programme received a lot of press around the world when it was enacted in July 2010. Offering up to 30 percent of any money recovered by the government from lawsuits of more than $1 million, there was much controversy that whistleblowers will be more incentivised to bypass their internal reporting systems and report directly to the government.

The latest report from the U.S. Office of the Whistleblower has shown these fears to be somewhat misguided, with a sharp increase in year-over-year reports from FY2011 to FY2012 but only a small year-over-year increase in FY2013. Further, these reports yielded only six awards in the past three years. With no real evidence that it will increase the amount of high-quality disclosures received by U.K. regulators as well as the cost and the complexity of setting up a government entity to process the reports and the bounties, the commission sees very little benefit to introducing financial incentives.

A New Whistleblowing Landscape in the U.K.

Despite the rejection of financial incentives, the commission vehemently supports increased regulatory changes “to require firms to have effective whistleblowing procedures, and to make senior management accountable for delivering these.” Later this year the commission will publish proposals on whistleblowing, including requiring firms to have effective mechanisms for employees to raise concerns and be protected from retaliation. Their aim is “to ensure that the culture in firms is one where people are prepared to speak up, as part of improving behaviour…”

Employers in the U.K. should be responding now to increased parliamentary focus around whistleblower culture.

Creating a Speak-Up Culture

For your compliance programme to be effective, employees must feel empowered to speak up. Empowerment thrives in a culture of trust, integrity, and transparency—one where employees feel an obligation to report others who are putting the organisation at risk.

Having an anonymous whistleblowing hotline service as well as more-advanced incident-reporting methods is the first step in creating this kind of culture. Many organisations also use incident management software to capture reports and ensure consistent incident resolution. Organisations must also communicate these values. This includes updating and distributing whistleblowing policies and periodically training employees on their duty to report and training managers on how to handle complaints and prevent retaliation.

Culture change does not happen in a day—it is a continuous process, and the message must be habitually reinforced from the top down to everyone in the organisation. With new whistleblower legislation on the horizon in the U.K., it is a process that organisations should start now.

To learn more about creating a culture of compliance, read our whitepaper, Creating a Culture of Ethics, Integrity & Compliance: Seven Steps to Success.


Written by:

NAVEX Global

NAVEX Global on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
Privacy Policy (Updated: October 8, 2015):

JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources. Our policies with regard to data collection and use of personal information of users of the Service, regardless of the manner in which users access the Service, and visitors to the Website are set forth in this statement ("Policy"). By using the Service, you signify your acceptance of this Policy.

Information Collection and Use by JD Supra

JD Supra collects users' names, companies, titles, e-mail address and industry. JD Supra also tracks the pages that users visit, logs IP addresses and aggregates non-personally identifiable user data and browser type. This data is gathered using cookies and other technologies.

The information and data collected is used to authenticate users and to send notifications relating to the Service, including email alerts to which users have subscribed; to manage the Service and Website, to improve the Service and to customize the user's experience. This information is also provided to the authors of the content to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

JD Supra does not sell, rent or otherwise provide your details to third parties, other than to the authors of the content on JD Supra.

If you prefer not to enable cookies, you may change your browser settings to disable cookies; however, please note that rejecting cookies while visiting the Website may result in certain parts of the Website not operating correctly or as efficiently as if cookies were allowed.

Email Choice/Opt-out

Users who opt in to receive emails may choose to no longer receive e-mail updates and newsletters by selecting the "opt-out of future email" option in the email they receive from JD Supra or in their JD Supra account management screen.


JD Supra takes reasonable precautions to insure that user information is kept private. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. However, please note that no method of transmitting or storing data is completely secure and we cannot guarantee the security of user information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.

If you have reason to believe that your interaction with us is no longer secure, you must immediately notify us of the problem by contacting us at info@jdsupra.com. In the unlikely event that we believe that the security of your user information in our possession or control may have been compromised, we may seek to notify you of that development and, if so, will endeavor to do so as promptly as practicable under the circumstances.

Sharing and Disclosure of Information JD Supra Collects

Except as otherwise described in this privacy statement, JD Supra will not disclose personal information to any third party unless we believe that disclosure is necessary to: (1) comply with applicable laws; (2) respond to governmental inquiries or requests; (3) comply with valid legal process; (4) protect the rights, privacy, safety or property of JD Supra, users of the Service, Website visitors or the public; (5) permit us to pursue available remedies or limit the damages that we may sustain; and (6) enforce our Terms & Conditions of Use.

In the event there is a change in the corporate structure of JD Supra such as, but not limited to, merger, consolidation, sale, liquidation or transfer of substantial assets, JD Supra may, in its sole discretion, transfer, sell or assign information collected on and through the Service to one or more affiliated or unaffiliated third parties.

Links to Other Websites

This Website and the Service may contain links to other websites. The operator of such other websites may collect information about you, including through cookies or other technologies. If you are using the Service through the Website and link to another site, you will leave the Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We shall have no responsibility or liability for your visitation to, and the data collection and use practices of, such other sites. This Policy applies solely to the information collected in connection with your use of this Website and does not apply to any practices conducted offline or in connection with any other websites.

Changes in Our Privacy Policy

We reserve the right to change this Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our privacy policy will become effective upon posting of the revised policy on the Website. By continuing to use the Service or Website following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Policy, as it may be amended from time to time, in whole or part, please do not continue using the Service or the Website.

Contacting JD Supra

If you have any questions about this privacy statement, the practices of this site, your dealings with this Web site, or if you would like to change any of the information you have provided to us, please contact us at: info@jdsupra.com.

- hide
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.