Strategy & Governance · 4 min read
Is Your Speak-Up Culture Working? How to Tell
Almost every organisation has a whistleblowing policy. Far fewer have a culture where people actually use it, or raise concerns informally before problems grow. Here is how to tell which kind you have.

When serious failures come to light, whether fraud, safety lapses, misconduct or cover-ups, investigations often find that someone knew. People had noticed something wrong, but did not raise it, or raised it and were ignored, or raised it and suffered for it.
A speak-up culture is one where people feel able to raise concerns early, through informal conversations with their manager as well as formal channels, and are confident that concerns will be taken seriously and that they will not be punished for raising them. It is one of the most important defences an organisation has against misconduct and failure, and one of the hardest to judge from the top.
This article sets out how to tell whether your speak-up culture is genuinely working, and what to do if it is not.
A policy is not a culture
Most organisations have a whistleblowing policy, a hotline and a statement that retaliation will not be tolerated. In many places, laws require some of this. These are necessary, but they say little about whether people actually feel safe speaking up.
The real test is behaviour: do people raise concerns, early and often, about small things as well as large ones? Do they trust what happens next?
Signs your speak-up culture is healthy
- Concerns are raised regularly, through a mix of channels, including directly with managers.
- Many concerns are about minor issues. This is a good sign: people are comfortable raising things before they become serious.
- People raise concerns openly, with their names, rather than mainly anonymously.
- Leaders talk about concerns raised, the themes and what changed as a result, without identifying individuals.
- Bad news travels up quickly. Problems reach senior leaders early, not after they have escalated.
- People who speak up are visibly supported, and their careers do not suffer.
Warning signs
- Very few reports. Low numbers are often read as good news. More often, they mean people do not trust the process or do not know about it.
- Reports arrive mainly through external routes, such as regulators, the media or lawyers, rather than internal channels.
- Mostly anonymous reporting, suggesting people fear being identified.
- Concerns surface late, often at exit interviews or after someone has left.
- The same issues come up repeatedly, suggesting earlier concerns were not addressed.
- Survey responses show low confidence that concerns will be acted on, or fear of consequences.
Measures that help
No single number tells the full story, but together these give a reasonable picture:
- Volume and trend of concerns raised, relative to the size of the organisation.
- Channels used: managers, hotline, HR, compliance, external.
- Proportion anonymous versus named.
- Types of concern, and whether the mix changes over time.
- Time to acknowledge and resolve concerns.
- Proportion substantiated, recognising that unsubstantiated concerns raised in good faith are still valuable.
- Reports of retaliation, and how they were handled.
- Survey questions such as "I feel safe raising concerns" and "I am confident action would be taken."

Strengthening speak-up culture
Train managers to listen
Most concerns are, or should be, raised first with a line manager. How managers respond determines whether people try again. Train them to listen, thank the person, avoid defensiveness, act or escalate appropriately and follow up.
Offer several trusted channels
Not everyone can raise a concern with their manager, especially if the manager is part of the problem. Offer alternatives: another manager, HR, a dedicated team, and a confidential or anonymous route operated independently.
Respond well and close the loop
Acknowledge concerns quickly, keep people informed where possible and tell them the outcome, even if details must remain confidential. People who hear nothing assume nothing happened.
Take retaliation seriously
Retaliation can be subtle: exclusion, lost opportunities, unfair performance ratings. Monitor what happens to people who raise concerns, and act firmly when retaliation occurs.
Lead by example
Leaders set the tone by inviting challenge, thanking people for raising difficult issues and talking openly about mistakes. If leaders react badly to bad news, people stop bringing it.
Share what changed
Regularly communicate the themes of concerns raised and the actions taken, while protecting confidentiality. Visible change is the strongest encouragement to speak up.
Speak-up and fraud prevention
Tips from employees, suppliers and customers are among the most common ways fraud and misconduct are discovered. A strong speak-up culture is therefore one of the most cost-effective fraud controls available. Our article on payment diversion fraud covers related controls for finance teams, including making it safe to challenge unusual requests.
How mature is your approach?
The Ethics & Integrity assessment covers ethical leadership, codes of conduct, decision-making, reporting and whistleblowing, conflicts of interest, and accountability.
Updated October 2026: our new Fraud & Financial Crime assessment includes a dedicated area on culture, awareness and speak-up, alongside prevention, detection and investigation.
Frequently asked questions
Is a low number of whistleblowing reports a good sign?
Rarely. It more often indicates low awareness or low trust. Healthy organisations tend to see a steady flow of concerns, many of them about relatively minor issues.
Should we allow anonymous reporting?
Yes. Some people will only raise concerns anonymously, especially at first. But a high proportion of anonymous reports can signal fear, so work towards a culture where people feel safe giving their names.
Who should oversee speak-up arrangements?
The board or a board committee should oversee speak-up arrangements, receive regular reports on themes and trends, and make sure concerns about senior leaders can be raised independently.