The new Whistleblower Protection Act was approved on 20 December 2022 and will enter into force in the beginning of 2023. Pursuant to the new Act, organisations that regularly employ over 249 people must establish an internal reporting channel within three months of the act entering into force. Companies and some other organisations, mainly in the private sector, employing 50–249 people have until 17 December 2023 to establish a reporting channel. Organisations employing fewer than 50 people can adopt a reporting channel voluntarily.
The Act is based on the EU Whistleblower Directive. It obligates large and medium-sized enterprises as well as public sector actors to establish an internal reporting channel through which the personnel, for example, can report suspected misconduct.
We discussed the basis and scope of application of the Act as well as establishing a reporting channel in our earlier blog. In this blog, we will focus on how companies should process the reports.
An organisation must acknowledge to the whistleblower that a report has been received within three days of receiving the report. It must also inform the whistleblower of the measures the report will lead to within three months of receiving the report. When providing this information to the whistleblower, the time and manner of reporting on measures must be evaluated on a case-by-case basis. In addition to the confidentiality obligations, any...
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