How whistleblowing strengthens organisations

According to the PwC Global Economic Crime Survey 2024,^[1] 41% of respondents observed stricter anti-corruption laws and enforcement in their jurisdictions. This trend is reflected in the recognition of enforcement agencies: in 2024, the Swiss Office of the Attorney General (OAG) was recognised as ‘Enforcement Agency of the Year’ by Global Investigation Review (GIR) for its success with cases against Swiss companies involving international corruption, bribery and money laundering, resulting in fines and restitution exceeding CHF 100 million.^[2]

The growing importance of whistleblowing programmes and global regulatory requirements underscores the increasing pressure on companies to enhance transparency and preventive measures to effectively combat economic crime as reflected in the following examples:

Switzerland’s reporting culture remains reserved, as highlighted by a 2021 study from the Institute of Business Ethics. According to the Ethics at Work: 2021 International Survey of Employees,^[8] only 41% of employees in Switzerland who observed fraud or misconduct would report it. Given that cultural shifts typically occur slowly, it is likely that many cases of fraud and misconduct in Switzerland will remain undiscovered in 2025. 

Unlike the EU and the US, Switzerland still lacks clear legal protections for whistleblowers. A revised legislative proposal from the Federal Council was rejected by Parliament in 2020 after more than a decade of debate, primarily due to the absence of dismissal protections and the perceived complexity of the regulations.^[9] In 2024, the National Council once again voted against a new whistleblower proposal.^[10]

Aside from Article 22a of the Federal Personnel Act^[11] and cantonal personnel regulations, there is no comprehensive protection for whistleblowers in Switzerland. The OECD has urged Switzerland to implement reforms to better protect whistleblowers in the private sector and to increase penalties for companies involved in the bribery of foreign officials.^[12]

A general rule of thumb suggests that organisations should expect three to five whistleblowing reports per 1,000 employees annually. If such reports are absent, companies should critically assess whether their employees feel safe enough to report misconduct. Unreported incidents can have serious consequences: risks remain undetected, necessary countermeasures are not implemented and governance weaknesses persist. 

To prevent whistleblowers from turning to the public or external authorities, companies must act early and proactively. Encouraging employees to report misconduct internally is essential for identifying and addressing issues promptly – ensuring the company remains agile and its reputation intact.

Implementing a whistleblowing hotline involves far more than setting up an email address and drafting a policy. It requires building robust governance structures, developing clearly defined processes and creating the right environment for success. Equally important is targeted and transparent communication, so employees perceive the initiative as a commitment to transparency and integrity – not as a sign of mistrust or a reaction to a specific incident.

Based on our experience and best practices, seven key success factors can be identified: 

• Tone from the Top: Leadership must take a clear stance and actively promote a culture of openness and integrity to build employee trust.
• Corporate Culture and Communication: A positive corporate culture, supported by regular communication and targeted training, fosters an environment where employees feel safe reporting misconduct. 
• Secure and Accessible Reporting Channels: Confidential, easily accessible reporting channels that operate independently of organisational hierarchies are essential. 
• Protection and Support for Whistleblowers: Measures to protect whistleblowers’ identities and prevent retaliation are critical. 
• Effective Response Mechanisms: Reliable triage and professional investigations by a qualified team are crucial. Both whistleblowers and accused parties must be treated fairly. 
• Feedback and Closure: Insights gained should be systematically used to promote organisational learning and drive continuous improvements in processes and structures. 
• Close Collaboration with HR: The HR department should be closely involved, particularly in supporting affected individuals and implementing measures.

Effective whistleblowing management relies on a combination of technical infrastructure, clear processes and a supportive corporate culture. These core elements help organisations detect misconduct early, respond appropriately, minimise damage and foster a long-term culture of integrity. 

An effective whistleblowing system also protects Swiss companies with international operations from cross-border enforcement actions, while promoting compliance and transparency. Beyond safeguarding against fraud and misconduct, a well-implemented whistleblowing system provides valuable insights into other critical areas, such as sustainability risks, cybersecurity threats and violations of internal policies. It strengthens compliance, mitigates risks and enhances resilience in an increasingly regulated business environment.