Insurance firms in the UK should allocate some time during 2014 to look over their whistleblowing arrangements, for whistleblowing is going to be the subject of increased scrutiny during the next twelve months (see this blog post about two waves of whistleblowing reform).
Such a review makes sound business sense, for whistleblowing acts as a form of early warning system for misconduct, wrongdoing or dangerous behaviour. Better to address such problems sooner rather than later, before financial and reputation costs start to stack up.
So what should a typical insurance firm be looking for? Here are 13 suggestions:
- does your firm have a whistleblowing policy?
- does your firm have a clear set of procedures for responding to any concerns raised by someone ‘blowing the whistle’?
- has the scope and wording of that policy and its procedures been reviewed within the last three years, and is there any evidence to show that those findings have been acted upon?
- does someone have clear responsibility for managing your firm’s whistleblowing arrangements?
- has anyone in your firm received any training in whistleblowing in the last three years?
- is a log kept of whistleblowing incidents and how they are being dealt with?
- when was the last time your senior management team reviewed that log of whistleblowing incidents?
- does the volume, nature and timescales of reported incidents look reasonable for a firm of your size?
- has anyone ever asked staff for their opinion about the trustworthiness of the firm’s whistleblowing arrangements?
- has anyone in your senior management team talked with staff about the importance of whistleblowing during the last two years?
- do the last three years’ minutes of your firm’s board contain any reference to whistleblowing?
- do you know of any incidents that you could have expected to have been raised through your firm’s whistleblowing arrangements?
- have you heard of any incidents of victimisation or breach of confidentiality having occurred in relation to a person who has ‘blown the whistle’?
Insurance firms may be tempted to just address the first point, about having a whistleblowing policy. After all, the main change they’ll see this year will be the regulator making such a policy compulsory for all but the smallest of firms. Avoid that temptation, for it will be short sighted and the FCA is likely to pick up on it as such. They’ll be looking for evidence not only that you’ve checked the soundness of your whistleblowing policy, but that you’ve also checked to see if it is delivering the outcomes for which it was intended. In other words, that your policy is the first link in a chain of responsibility to people who have blown the whistle, people who have bought from your firm, and people who have invested in your firm.
This 13 point checklist will guide you along that chain of responsibility.