Whistleblowing FAQs

What is whistleblowing?

Whistleblowing is a term used to describe the action of an employee, consultant or contractor disclosing information about a wrongdoing which they have discovered occurring within their organization. This could include reports of accounting or auditing fraud, breach of the organization’s policies or code of conduct or other criminal activities.

Why do I need a whistleblowing policy?

For reporting issuers in Canada, National Instrument 52-110 – Part 2 states that an audit committee is responsible for establishing a procedure for the confidential, anonymous submission by employees of concerns regarding questionable accounting or auditing matters. For private companies and not for profit organizations a whistleblowing policy is a good governance practice that can be invaluable in attracting and retaining shareholders and stakeholders.

Why do I need an external whistleblower service?

While it may seem like simply setting up a telephone/fax hotline and an email address internally is all that is necessary, it is important to consider how this will be received by potential whistleblowers and by the public. Will a potential whistleblower trust that they will remain truly anonymous and if not will they still file a report?

By using an external, third-party whistleblowing service, your organization can be confident in the knowledge that if a complaint is made that it will be received by an unbiased source and that any contact information included in the report will not be forwarded to the company (unless directed by the whistleblower). All communications and report follow-ups will be filtered through Cornerstone, providing assurance to potential whistleblowers that their anonymity is being protected.

Who will receive the complaint?

Depending on the type of complaints you receive, you may want to designate one or more people to receive complaints for investigation. Typically all financially related matters will be directed to the chairperson of the audit committee; however they may not be the most practical designate to receive human resource related reports.

What types of complaints can I expect to receive?

The original intention of whistleblower policies and hotlines was to receive information regarding questionable accounting and auditing practices, but most policies have evolved to also encourage reports of a breach of the organization’s policies or code of conduct, environmental hazards, theft or other criminal activities.

What happens when a complaint is submitted?

Once a report is submitted, a representative from Cornerstone Governance Corporation will review and forward it to the designated investigator. If the complaint was submitted via our website the whistleblower will receive a ticket number which will allow them to log back in to follow up on their report and add additional information if necessary. If the organization would like to follow up with the whistleblower, questions can be submitted to Cornerstone and we will communicate with the whistleblower via the website allowing the whistleblower to continue to remain anonymous.