On 14 November the FCA published a review of firms’ whistleblowing arrangements in retail and wholesale banking. The review was conducted to identify how well the firms implemented the whistleblowing rules published by the FCA back in September 2016.
The supervisory review analysed firms’ policies and procedures, training arrangements, whistleblowing annual reports and the role of the whistleblowers’ champions. Based on this information the FCA outlined good practice and areas for improvement. The key finding of the FCA are as follows:
All firms have updated their policies with some putting emphasis on protecting a whistleblower from victimisation and ensuring confidentiality throughout the process. However, some firms still need to improve or develop further appropriate arrangements to protect whistleblowers from victimisation;
A small number of firms have developed step-by-step investigation processes but the majority need to improve their investigation processes to enhance consistency of escalating concerns;
A number of firms misled their employees by stating that they must first raise their whistleblowing concerns with their employer before contacting the FCA;
All the firms aim to provide feedback to a whistleblower and all have appointed an independent whistleblowers’ champion amongst their non-executive directors;
Some firms provided insufficient information and analysis in their whistleblowing annual reports;
All firms provided training to their employees on whistleblowing. However, most of the firms need to improve the detail of the training they provide and to differentiate their training depending on the seniority of employees.
The FCA concluded that, overall, regulated firms are going in the right direction even though there are areas that need to be improved. The FCA acknowledges the importance of ensuring that employees should feel safe to blow a whistle as it serves as a deterrent to those who wish to commit prohibited activities.