If your company meets any of the conditions outlined above, you must implement an internal reporting procedure.<\/p>\n
We have written here<\/strong><\/a> about the specific duties employers have to protect whistleblowers.<\/p>\n A whistleblower is a person who reports or publicly discloses information about a legal violation in a work-related context or in connection with their work for or cooperation with a company<\/strong>. The range of people who may qualify is very broad<\/strong><\/a>. A whistleblower may be:<\/p>\n From an employer\u2019s perspective, internal reports are especially important: they are made within the company rather than, for example, directly to the prosecutor\u2019s office. A whistleblower is a person connected with your company who internally reports irregularities or violations of the law<\/strong><\/a> they have noticed in the organization.<\/p>\n Our article on how to receive and verify reports explains the employer\u2019s side of managing a report.<\/p>\n Companies must enable whistleblowers to make reports. You cannot organize the process however you like: the Act sets out rules you must implement to enable reports of irregularities. It also sets out protections against retaliation by the employer or other people in the company.<\/p>\n The Act is not optional<\/strong>: if your company meets the specified conditions, you must implement the Whistleblower Support Program<\/strong><\/a>.<\/p>\n Before the final draft of the Act was published, there was uncertainty about whether the 50-person threshold counted only employees under employment contracts or also people working under B2B, service or specific-task contracts. The difference can be substantial: some companies \u201cemploy\u201d hundreds of people exclusively on invoices.<\/p>\n The legislature clarified this in the final provisions.<\/p>\n The threshold includes employees under employment contracts and people providing work under:<\/p>\n In addition to companies with more than 50 employees under employment contracts, the following must also implement a whistleblower protection system, among others:<\/p>\n This applies if they employ at least 50 people in the forms listed above.<\/p>\n There are exceptions to the 50-person rule. The Act lists entities that must implement whistleblower provisions even if they have fewer than 50 employees.<\/p>\n The 50-person threshold does not apply to entities operating in financial services, products and markets; anti-money laundering and counter-terrorist financing; transport safety; and environmental protection, where they are covered by EU legal acts listed in Parts I.B and II of the Annex to Directive 2019\/1937.<\/p>\nWho is a whistleblower?<\/h2>\n
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Internal reports: what they mean for employers<\/h3>\n
Which companies does the Whistleblower Protection Act cover?<\/h2>\n
How to count 50 people under the Whistleblower Protection Act<\/h2>\n
Who counts toward the 50-person threshold?<\/h3>\n
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Who is covered: summary of the 50-person threshold<\/h3>\n
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Who must implement the Whistleblower Protection Act regardless of workforce size?<\/h2>\n
Which companies must implement the rules regardless of workforce size?<\/h3>\n
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Whistleblowers and AML-obliged institutions<\/h2>\n