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Do you need a whistleblowing channel, and how much of one?

Answer 10 short questions about your organisation. You get an honest answer, also when the answer is that you need nothing more than a written routine.

Four possible answers

  1. 1The legal minimum
  2. 2A secure channel
  3. 3An outside receiver
  4. 4Investigation support

As you answer, you see where you land. General information, not legal advice.

Question 1 of 10 · Volume How many people does your organisation regularly employ?

Count permanent and temporary employees.

Why we ask

Organisations that regularly employ at least five people must have a written routine for reporting censurable conditions. Smaller ones must too if conditions call for it. aml § 2 A-6 (1)

Question 2 of 10 · Exposure Which describes your organisation?
Why we ask

Public bodies spend public money and exercise authority, so a hidden wrong costs public trust. Regulated sectors answer to a supervisory authority that employees may always report to. aml § 2 A-2 (2)

Question 3 of 10 · Exposure What do your people handle at work?

Choose everything that applies.

Why we ask

The law's examples of censurable conditions include danger to life or health, corruption and other economic crime, abuse of authority, and breach of personal data security. The more of these your work touches, the more a report can matter. aml § 2 A-1 (2)

Question 4 of 10 · Distance Who would receive a report today?

The honest answer, not what the handbook says.

Why we ask

The people who investigate a report must be impartial. When the employer is not, it can use outside help. In a small organisation the receiver is often the manager the report is about. Arbeidstilsynet: Slik bør arbeidsgiver håndtere varsling

Question 5 of 10 · Distance If a report concerned your top manager, where would it go?
Why we ask

Arbeidstilsynet lists "who do you report to if the report concerns the top manager?" as a question every routine should answer. Arbeidstilsynet: Virksomheten skal ha rutiner for intern varsling

Question 6 of 10 · Distance How often would people want to report without giving their name?

Think of small teams where everyone knows each other, strong hierarchies, or someone who was treated badly after speaking up.

Why we ask

Employees have the right to report anonymously, and an anonymous report must still be followed up. That only works if you can write back to someone whose name you do not know. Arbeidstilsynet: Spørsmål og svar om varsling

Question 7 of 10 · Volume Who besides your own employees works in your organisation?

Choose everything that applies.

Why we ask

Hired-in workers may report on the business they are placed in, and trainees and students are covered by the same rules. Contractors are not named in the law, but they see a lot. Each group needs a way in that does not depend on your intranet or on reading Norwegian. aml § 2 A-1 (1), aml § 1-6 (1)

Question 8 of 10 · Volume How many reports do you expect in a year?

Count reports of censurable conditions, not ordinary complaints.

Why we ask

A handful of reports a year can be handled by one careful person. More need deadlines, a shared view of who is doing what, and a log that shows it was done. "None" often means people do not trust the channel, not that nothing happens.

Question 9 of 10 · Readiness gap Do you have a written whistleblowing routine?
Why we ask

The routine must be written, made together with the employees and their union representatives, and easy for everyone to find. aml § 2 A-6 (2), (4), (5)

Question 10 of 10 · Readiness gap If a serious report came in tomorrow, who would investigate it?
Why we ask

The employer must see that a report is sufficiently investigated within reasonable time, and must hear the person reported on before concluding. aml § 2 A-3 (1), Arbeidstilsynet: Slik bør arbeidsgiver håndtere varsling