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Sustainability Command Center 15 items

EU Whistleblower Directive Compliance Checklist

Assess internal reporting channels and case handling against the EU Whistleblower Protection Directive (2019/1937) and ISO 37002 good practice.

EU Directive 2019/1937ISO 37002:2021

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Scope & Obligation

  • Has it been confirmed the entity meets the 50-employee threshold (or other trigger) requiring internal channels? *
  • Is the material scope of reportable breaches (Union law areas plus any national extensions) defined? *
  • Are the categories of persons protected (workers, contractors, applicants, facilitators) identified? *

Internal Reporting Channels

  • Are secure internal reporting channels available in writing, orally, or both? *
  • Is an impartial person or department designated to handle reports? *
  • Can reports be made anonymously where national law provides for it? *

Case Handling Timeframes

  • Is receipt of a report acknowledged within seven days? *
  • Is feedback provided to the reporting person within three months? *
  • Is diligent follow-up on reports conducted and documented? *

Confidentiality & Data Protection

  • Is the identity of the reporting person kept confidential and access restricted? *
  • Is personal data processed in line with GDPR and unnecessary data not collected? *
  • Are records of reports retained per retention rules? *

Non-Retaliation & Awareness

  • Are prohibitions on retaliation and support measures for whistleblowers in place? *
  • Is information on internal and external reporting channels clear and accessible to staff? *
  • Are staff who handle reports trained and is the process periodically reviewed for effectiveness? *

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