FCA has published its review of how firms implement FCA whistleblowing rules. Its review covered a range of wholesale and retail banks. It found several areas of both good and poor practice to comment on, and now urges all firms to review the report and consider what steps they may need to take to improve their whistleblowing arrangements.
FCA found that, on the whole, firms do have policies that are fair and protect individuals, and that the NEDs who act as whistleblowing champions are providing independent oversight. These individuals showed good understanding of their role and had taken proactive action to ensure the policies worked. Most firms had also carried out reviews of their policies.
FCA is pleased that firms had either implemented or updated policies and procedures to reflect FCA rules and many had a clear policy and arrangements for ensuring whistleblowers were protected against victimisation. Most also had policies for secure storage of relevant information.
That said, it also found that many firms had not fully considered or implemented the SYSC 18 requirements and needed generally better to document their approach. It was also concerned that some firms could not adequately show how whistleblowers would be protected. Also, while most firms had a variety of channels for possible reporting, including third party anonymous hotlines, some firms required an internal report before any contact with FCA.
All firms provided training, but FCA felt most needed to improve the detail provided in it, and many needed to separate training for managers on the one hand and investigation teams on the other.