If you don't inform employees about the whistleblowing procedure, the channel exists on paper but isn't used in practice. Employees who want to report a wrongdoing don't know there's an internal route, and are more likely to approach a colleague, the media or a regulator instead. This means the organization misses the opportunity to catch a signal early and internally, and that's precisely what the whistleblowing procedure is legally designed to prevent.
The obligation to have a reporting channel is not separate from the obligation to inform employees about it. A procedure that sits on a server somewhere but is never shared doesn't meet the principle that an employee can actually find the way to the channel. This is one of the points that can be examined in a dispute or inspection.
Why informing is not a formality
The purpose of the whistleblowing procedure is to give an employee who has doubts about a wrongdoing a safe and familiar place to report it. This function only works if the information actually reaches people: where the channel is located, how a report is handled, and what protection an employee can expect. Without that information, the channel exists in theory, not in practice.
In practice, this usually means that the procedure has a fixed place on the intranet or in the staff handbook, that new employees are made aware of it upon recruitment, and that the information is also accessible to people who find it harder to follow digital information, such as employees on the shop floor without a fixed workplace. the knowledge base with explanations on each topic describes what is concretely involved.
The risks laid out clearly
The direct risk is that a report doesn't reach you through the internal channel, but through a roundabout way: an external regulator, the press, or much later when a situation has already escalated. That's more troublesome for all parties than when a report comes in early and internally.
A second risk applies in a dispute afterwards. If an employee claims they didn't know where to go, and the organization cannot show that the information was shared, that's a weak point in the file. This is not an established penalty, but something that weighs in the assessment of whether the organization has fulfilled its obligation properly.
A third risk is internal trust. A whistleblowing procedure that nobody knows about gives the impression that integrity is not a priority. That's harder to restore than a missing document, because it's about the culture on the shop floor.
What is and isn't legally established
The obligation to inform employees is part of the broader whistleblowing obligation for organizations above the legal threshold. How detailed that information must be and in what form is not prescribed in detail; the essence is that the information is actually available and understandable to everyone who should be able to use it. For a precise explanation of your situation, it's wise to consult a lawyer or consult the legislation itself.
Curious whether this applies to your organization and what concretely needs to be in place? do the free check in a few questions and immediately see an indication of your situation.
How to solve this in practice
Fixing missing or incomplete information provision is usually not a major undertaking. It's about clear, findable text about the channel, a fixed place where employees can find it, and a moment when new employees are informed about it. Signalo provides a ready-made information kit for this that you can adapt to your own organization, so you don't have to formulate from scratch what exactly needs to be included.
It is also worth checking whether the works council has already approved the reporting procedure itself, as that approval and the provision of information to employees go hand in hand. You will find more about that process in the frequently asked questions about the reporting rules.
Do you want to put this part in order all at once, including communication to employees? First do the free check on signalo.eu, or open a business account to get started directly with the documents and the information kit.