The FCA has launched a campaign encouraging individuals working in financial services to report potential wrongdoing to the FCA and reminding them of the confidentiality processes in place. As part of the campaign, the FCA has published materials for firms to share with employees, as well as using its events to highlight the campaign.
The FCA has also produced a digital toolkit http://www.fca.org.uk/firms/whistleblowing/speaking-fca for industry bodies, consumer groups and whistleblowing groups to encourage individuals to have confidence to step forward.
Whistleblowers who report to the FCA will have a dedicated case manager. They can meet with the FCA to discuss their concerns and can receive optional regular updates throughout the investigation. The FCA says it will review every report it receives and protect individual whistleblowers’ identities.
“The Whistleblowing team create and record a report of your concerns − it focuses on the concerns, not the person who reported them.”
It has long been a concern that the first person who gets investigated is the whistleblower herself. Even now, we suggest that potential whistleblowers seek advice externally before reporting. After all, if you worked at the firm, you’re implicated. But you need to balance this with your own obligations to society, and to the FCA under principle 11, and the opportunity to at least limit the damage if you are involved in any way. Any serious study of the banking crash needs to take into account the ruined career of HBOS whistleblower Paul Moore. https://en.wikipedia.org/wiki/Paul_Moore_(banking_manager). He played the system with a straight bat, and the system was not kind to him.
Almost all organisations have a “fit in or fuck off” mentality, and it is remarkably rare for any business founder to create a culture that not only has a gravity of its own – as they all do, but also allows for internal criticism. Of course you should make sure that all employees have a copy of your own whistleblowing policy. See template on IFAC's BAT doc library
This move by the FCA is long overdue, and provides a link out of the organisation to the very top.
It is part of the wider move under the SM&CR that seems to be dragging us all towards being virtual employees of the FCA – without their pay of course - protected from competition by their actions. Be that as it may, this whistleblowing move is thirty three years overdue.
See also the IFAC public interest disclosure paper on BAT document library- available for members of IFAC only.