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ICC 2022 Guidelines on Whistleblowing



The purpose of these Guidelines is to help Enterprises establish and implement a Whistleblowing Management System, by offering practical guidance that will serve as a useful point of reference. The original ICC Guidelines on Whistleblowing were published in 2008 and this update incorporates current experience and practice of ICC member Enterprises across a wide range of sectors and jurisdictions worldwide. They have been aligned with key international legal instruments as well as global standards and best practice for Whistleblowing Management Systems1 .


Whistleblowing is the act of reporting a Wrongdoing.

Unaddressed, such harm can erode the trust of the stakeholders in the Enterprise’s governance and can destroy the Enterprise’s shareholder value.


Employees of an Enterprise and those in close contact with them (including Business Partners and other Third Parties) are often the first to recognize a potential Wrongdoing or risk of harm. They are therefore valuable sources of information and well placed to support resolving a potential problem early on before it causes material damage to the Enterprise and the society.


It is therefore in the interest of a responsible Enterprise to encourage Whistleblowing as part of its Ethics & Compliance Programme, or its ethics guidance, and to set up a system to support Whistleblowing. A well functioning and trusted Whistleblowing Management System supports Enterprises’ ambitions for sound risk management, internal control and effective compliance, and promotes a culture of transparency, integrity and accountability.


While the term “Whistleblower” can awaken different feelings in different countries, it has today become an internationally recognized term to denote persons who report suspected or actual Wrongdoings. Therefore, Whistleblowing can in a corporate context range from raising concerns, speaking up or submitting a confidential report via an Enterprises’ Whistleblowing channel.


Enterprises today are, among other criteria, measured by how they deal with Whistleblower and how well they handle reports and concerns that are brought to their attention. The ICC Rules on Combating Corruption recommend that Corporate Compliance Programmes adopted by Enterprises offer “confidential channels to raise, in full confidentiality, concerns, seek advice or report in good faith established or soundly suspected violations without fear of retaliation or of discriminatory or disciplinary action”.

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