ICC Document & publication

ICC Guidelines on Whistleblowing

Convinced that self regulation provides effective protection of corporate interests, ICC has developed over the years rules aiming at fighting corruption and other forms of economic fraud. In particular, ICC has encouraged companies to put into place efficient preventive policies which can shield them from the grave consequences economic fraud can entail.

The 2005 ICC Rules of Conduct on Combating Extortion and Bribery recommend that anti-corruption policies and codes adopted by enterprises should “offer confidential channels to raise concerns, seek advice or report violations without fear of retaliation.” This ICC Recommendation is extensively commented in Chapter Ten of the ICC Corporate Practices Manual “Fighting Corruption”, written by Michael N. Davies, Q.C.

ICC France has taken the initiative to issue guidelines on the important question of putting into place whistleblowing mechanisms in enterprises.

The purpose of these Guidelines is to help companies establish and implement internal whistleblowing programs, by setting forth practical indications, that can serve as a useful point of reference, while meeting, as much as possible, the objections formulated in certain countries about some aspects of a whistleblowing system. These Guidelines are based on the broad experience and practice of ICC member companies across a wide range of sectors and jurisdictions. They are also inspired by a large number of international and national legal provisions.