ICC Whistleblowing Guidelines to scale up business integrity

  • 25 February 2022

ICC has unveiled the newest contribution to its tools to help business stamp out corruption: the 2022 edition of the ICC Whistleblowing Guidelines.

Providing practical guidance to help enterprises establish and implement a Whistleblowing Management System, the guidelines are an update of the ICC Guidelines on Whistleblowing published in 2008, incorporating current experience and practice of ICC member enterprises across a wide range of sectors and jurisdictions worldwide. The 2022 edition also aligns with key international legal instruments as well as global standards and best practice such as the 2021 ISO 37002 Guidelines on Whistleblowing Management Systems and the 2019 European Directive on Whistleblower Protection, which is now being implemented by governments across Europe.

Viviane Schiavi, Global Policy Lead – Anti-corruption and Corporate Responsibility, emphasised that “a well-functioning and trusted Whistleblowing Management System supports enterprise objectives for sound risk management, internal control and effective compliance, and promotes a culture of transparency and accountability. It enables reporting through organised communication channels set out by the enterprise to ensure that concerns of wrongdoing swiftly reach those that are most able to investigate the matter and are empowered to remedy it.”

As employees are often the first to recognise a potential wrongdoing or risk of harm, they are valuable sources of information and well placed to help resolve a potential problem early on before it causes damage to the enterprise and society.

The ICC guidelines make clear that there is no “one-size-fits-all” solution and that the Whistleblowing Management System must be made part of the cultural environment and the governance of the enterprise.

Underscoring that non-retaliation against the whistleblower is the bedrock for an effective and trusted whistleblowing system, the guidelines help enterprises to evaluate whether to allow anonymous reporting, whether to accept reporting by third parties and/or the general public, and other criteria.

Hema Lehocky, Co-Chair of the ICC Working Group on Whistleblowing Guidelines and Chief Ethics and Compliance Officer at AFRY said: “A Whistleblowing Management System cannot work in isolation; it must be part of continuous efforts to build a strong foundation of ethics that encourages employees to speak up. Enterprises today are measured by how they deal with whistleblowers and how well they handle reports and concerns that are brought to their attention.”

Manuel Castelo Branco, Co-Chair of the ICC Working Group on Whistleblowing Guidelines and Counsel with Linklaters said: “The new edition of the ICC Whistleblowing Guidelines bolsters ICC’s crucial role on corporate compliance and is a concrete tool to help enterprises create a culture of integrity.”

The integrity tool reflects ICC’s commitment to supporting greater implementation of the United Nations Convention against Corruption (UNCAC) and delivers a concrete response to calls from G20 leaders for increased transparency and accountability in the face of the global pandemic crisis, set out in their G20 2022 – 2024 Anti-corruption Action Plan 

The ICC Whistleblowing Guidelines are applicable for enterprises of all sizes and sectors, private or public. Developed by business, for business, they are unique in comprising up-to-date guidance on setting up whistleblowing systems.

The guidelines were drafted by experts of the ICC Global Corporate Responsibility and Anti-Corruption Commission that groups over 400 business leaders from all sectors in over 40 countries worldwide.

Download the Guidelines