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Guidelines for Private and Public Sector

Guidelines for officers receiving internal reports referred to as Whistleblower Reporting Officer (WRO)
The following guidelines apply to units or officers receiving internal reports in both the public and private sector. 

What is the role of the WRO?  
​​The WRO is a designated impartial person or department competent for following-up on reports of improper practices or breaches of the law made by whistleblowers (reporting persons).  The WRO maintains communication with the whistleblower and, where necessary, asks for further information and provides feedback to the reporting person. 

The WRO cannot conduct the investigation as this could lead the WRO to divulge the identity of the whistleblower. Moreover, since the WRO is aware of the identity of the Whistleblower he/she may be prejudiced during the investigation.

Subject to the nature of the wrongdoing, the WRO is to seek advice, even legal advice if so required, and keep the Head of Department/Organisation informed without divulging the identity of the reporting person.​

What is protection?
The protection given to the whistleblower in the context of this legislation is confidentiality and anonymity of the reporting person, and any other persons aiding them (facilitators). 

It is crucial to note that protection is in the form of confidentiality and strict anonymity. Both the current Act and the directive prohibit the disclosure of the identity of the whistleblower, therefore no information that identifies the whistleblower shall ever be disclosed, “unless the whistleblower expressly consents in writing to the disclosure of that information.”
Who can achieve whistleblower status?
A whistleblower is a person working within the private or public sector who, through a “work-related context”, has acquired information regarding a breach of law and who, in the absence of special rules to protect them, is likely to face retaliation if they report it. This applies to current employees as well as those who have since left their position or who have not yet begun it. This should cover:​

    Employees of any kind, including public officials   
    Shareholders and people belonging to the administrative, management or supervisory body, including non-executive members, volunteers and paid/unpaid trainees  
    Any persons working under the supervision and direction of contractors, subcontractors and suppliers.​ 

Who is a facilitator?
A facilitator is a person who aids the whistleblower in their reporting of a breach or who is connected to the whistleblower and therefore likely to suffer retaliation in a work- related context. This includes third parties connected to the reporting and legal entities connected to the whistleblower in a work-related context.​
How can internal reports be made?  
Internal reports can be made:

    through a physical meeting   
    in writing (including complaint boxes)   
    orally through telephone lines or other vioce messaging systems
    online platform (internet or intranet)

An acknowledgement of receipt shall be given within 7 days and the whistleblower shall be given feedback on the follow up of the report within 3 months from receipt.

It is important to note that internal reports received by email can only be made through the generic email restricted solely to whistleblower cases.  These email accounts shall only be accessed by the WRO and must be monitored regularly. Other generic email accounts (such as customer care domains) shall not be used for whistleblower reporting since this breaches confidentiality​.



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