The Whistleblowers’ Champion: Who Should Hold the Role, and Why It Matters
At banks, building societies and larger insurers, the regulators require a whistleblowers’ champion: a named individual responsible for overseeing the firm’s whistleblowing arrangements. Many other firms appoint one voluntarily. Choosing the right person matters more than it might seem. The champion is often the board member staff trust most to take a concern seriously, and the one the regulator looks to when whistleblowing goes wrong.
Which Firms Need a Whistleblowers’ Champion
The FCA’s whistleblowing rules are in SYSC 18. They require relevant firms, broadly UK banks and building societies above a size threshold, PRA-designated investment firms and larger insurers, to appoint a whistleblowers’ champion. The PRA has equivalent requirements for the firms it regulates. Other regulated firms aren’t required to appoint one, but the FCA encourages them to treat the rules as good practice, and many do.
At firms that must have one, the responsibility is allocated to a Senior Manager as part of the Senior Managers and Certification Regime, so the champion is personally accountable for it.
What the Champion Does
- Oversees the integrity, independence and effectiveness of the firm’s whistleblowing policies and procedures.
- Oversees protection from victimisation for people who raise concerns.
- Reports to the board, at least annually, on the operation and effectiveness of the arrangements.
- Is a visible point of contact for staff who want to raise concerns outside their reporting line.
The champion oversees the arrangements. They don’t usually investigate concerns themselves, and they don’t replace the firm’s other speaking-up channels.
Who Should Hold the Role
The rules generally expect the champion to be a non-executive director, and in practice an independent non-executive is almost always the best choice:
| Candidate | Suitability | Why |
|---|---|---|
| Independent non-executive | Best choice | Independent of management; can challenge; trusted by staff |
| Chair of the board | Possible | Independent, but already has a heavy role; staff may find them less approachable |
| Audit or risk committee chair | Common | Already oversees control functions; check workload |
| Group non-executive on a subsidiary board | Use with care | May lack independence from the group |
| Executive director | Generally unsuitable | Not independent of the management being challenged |
What Makes a Good Champion
Genuine Independence
Staff need to believe that raising a concern with the champion won’t be passed straight to the people they’re worried about.
Credibility With Staff
The best champions are visible: they meet teams, explain the arrangements and make it clear they want to hear concerns.
Willingness to Challenge Management
The role sometimes means telling the chief executive that something is wrong. The champion needs the confidence and standing to do that.
Judgement About Patterns
Individual concerns often point to wider problems. A good champion asks what the themes mean for the firm’s culture and controls.
Time
The role adds to a non-executive’s workload. Check they can take it on alongside committee work.
The Champion’s Annual Report
The champion should give the board at least an annual report on the whistleblowing arrangements, covering:
Annual whistleblowing report checklist
- Number and nature of concerns raised, and through which channels
- How concerns were handled and resolved, and how long it took
- Any evidence of detriment to people who raised concerns
- Themes and what they suggest about culture and controls
- Awareness of the arrangements among staff
- Changes made as a result of concerns
- Any concerns reported to the regulators
- Recommendations for improving the arrangements
Legal Protection for Whistleblowers
Workers who make protected disclosures are protected by law under the Public Interest Disclosure Act 1998. Firms must also tell staff that they can report concerns directly to the FCA or PRA. The champion should make sure the firm’s arrangements, policies and settlement agreements are consistent with those protections.
A building society’s whistleblowers’ champion had been its chair for six years. A staff survey suggested many employees didn’t know who the champion was, and very few concerns were being raised. The board moved the role to its newest independent non-executive, who had a background in people and culture, and asked her to meet every department in her first year. Concerns raised through internal channels increased, which the board treated as a sign the arrangements were working.
If Your Board Has No Suitable Champion
Smaller boards, and subsidiary boards made up mainly of group executives, may have no one independent and credible enough for the role. The answer is usually to recruit an independent non-executive. NED Capital, a sister practice of SMF Capital, specialises in non-executive appointments. Where the new non-executive will also chair a committee and hold a Senior Manager Function, SMF Capital leads the search. See chair and committee chair recruitment and our page on non-executive directors at FCA-regulated firms.
Firms That Don’t Have to Appoint One
For firms outside the requirement, appointing a champion voluntarily is still worthwhile. It signals to staff and supervisors that the board takes speaking up seriously, and gives staff a clear route outside management. The same principles apply: choose someone independent, credible and willing to challenge.
Supporting the Champion
A champion can’t oversee the arrangements alone. They need regular information from whoever runs the whistleblowing process day to day, usually compliance, HR or internal audit, including anonymised details of concerns, how they were handled and how long they took. They also need direct access to the people involved and the authority to ask for reviews where something looks wrong. Firms should agree in writing what information the champion receives and how often, so the role doesn’t depend on informal goodwill.
Internal audit can provide valuable independent assurance, for example by periodically testing whether concerns are logged, investigated independently and closed properly. The champion should see the results and follow up any weaknesses found. Those findings belong in the annual report to the board.
Measuring Whether the Arrangements Work
Numbers alone rarely tell the story. A sudden fall in concerns may mean people have stopped trusting the process; a sudden rise may mean a problem, or simply that awareness has improved after a campaign. The champion should look at volumes alongside staff survey results, exit interviews, the proportion of concerns raised anonymously and how many concerns were substantiated. Comparing these over time, and between business areas, gives a much clearer picture than any single figure.
Common Mistakes
- Appointing by default, often the chair or longest-serving non-executive.
- An invisible champion staff have never met or heard of.
- A passive role that receives reports without testing whether the arrangements work.
- Treating low numbers as good news without asking whether people feel able to speak up.
- Ignoring themes across individual concerns.
Whistleblowing and the Board
Guides and services for boards overseeing speaking up. Every SMF search is led personally by Adrian Lawrence FCA
Board Roles
Independent non-executives and chairs.
→ NEDs at FCA-regulated firms
→ Chair and committee chairs
Accountability
Rules behind the role.
→ The Conduct Rules
→ Conduct Rules training guide
Board Pressures
Other board-level questions.
→ Consumer Duty champion
→ NED time commitment
Structure
Allocating Prescribed Responsibilities.
→ The Responsibilities Map
→ Governance structure review
Every SMF search is led personally by Adrian Lawrence FCA
Frequently Asked Questions
Does every regulated firm need a whistleblowers’ champion?
No. The requirement applies to relevant firms, broadly larger banks and building societies, PRA-designated investment firms and larger insurers. Others are encouraged to follow it as good practice.
Does the champion investigate concerns?
Usually not. They oversee the arrangements and their effectiveness, while investigations are carried out by others.
Can the chair be the whistleblowers’ champion?
Yes, but an independent non-executive with more time and approachability is often a better choice.
Is the champion personally accountable?
At firms required to have one, the responsibility is allocated to a Senior Manager, so yes.
About the Author
Adrian Lawrence FCA is the founder of SMF Capital. He is a Chartered Accountant and Fellow of the ICAEW, holds a practising certificate in his own name, and is a former listed-company Finance Director with a BSc from Queen Mary College, University of London. He founded FD Capital in 2018 and has since built a network of five specialist recruitment practices. He leads every SMF Capital board search personally, including independent non-executives taking on the whistleblowers’ champion role. View Adrian’s ICAEW profile.
Need an Independent Non-Executive for the Role?
SMF Capital and NED Capital help boards find independent, credible non-executives. Get in touch for a confidential conversation.
Adrian Lawrence FCA is the founder of SMF Capital and a Fellow of the Institute of Chartered Accountants in England and Wales and holds an ICAEW practising certificate in his own name. He holds a BSc from Queen Mary College, University of London, and has over 25 years of experience working with boards, investors and business owners across the UK. He founded SMF Capital to help FCA and PRA-regulated firms appoint the Senior Managers the regulators expect, with the fit and proper assessment built into every search, and personally leads every Senior Manager Function search.
