Handling whistleblowers in corporate internal criminal investigations: UK lawyers’ practical guide on policy, privilege, investigations and self-reporting

Published by a LexisNexis Corporate Crime expert

Practice notes

This Practice Note outlines the practical issues that can follow receipt of a whistleblower report from the viewpoint of the corporate entity receiving it (including limited companies, partnerships and LLPs). For guidance aimed at those representing whistleblowers, see Practice Note: Representing whistleblowers in internal criminal investigations. Reports may cover a broad range of suspected wrongdoing, from breaches of internal policy and employment matters such as discrimination, to allegations of serious criminality. The focus here is the latter, though some principles have wider relevance...

Whistleblowing policy

Benefits of implementing a whistleblowing policy

While whistleblowing legislation does not generally require companies to maintain a whistleblowing policy (with specific rules applying to listed companies and those in the financial services sector), creating and publicising clear, robust policies and procedures for dealing with whistleblowing is regarded as best practice and delivers several benefits:

It signals a psychologically safe corporate culture; promoting use of internal reporting routes and safeguarding those who speak up through them
It encourages the early reporting of issues...

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Ben Cooper

TLT

Ben leads TLT's economic crime team and has over 20 years' experience advising governments, financial institutions, corporates and individuals on all aspects of economic crime. This includes advice on money laundering, sanctions, tax evasion, bribery and corruption, terrorist proliferation financing, corporate ethics, asset tracing, fraud, complex investigations and criminal proceedings. Ben also has extensive experience assisting clients to develop, implement and operate global economic crime compliance programmes utilising his experience in senior compliance roles for HSBC, Global Head of Financial Crime Functions and Global Head of AB&C.Ben also worked for the Asset Recovery Agency and Serious Organised Crime Agency (now the National Crime Agency) and so is uniquely placed to advise clients on handling enquiries and investigations from law enforcement agencies....

Chantal Stroker

Partner, TLT

Chantal specialises in contentious financial regulatory work, litigation and legal project management. She is a Leading Partner in The Legal 500 and TLT’s EDI Champion. Chantal has been instrumental in developing TLT’s Financial Services Investigations and Contentious Regulatory practice from a standing start in 2017, into the market leading practice it is known as today. That practice handles some of the most significant and reputationally sensitive investigations and projects across the industry for an impressive and ever-growing client base.She is a disrupter in the market, being recognised as providing magic circle/City quality and experience out of the region. She has extensive experience advising financial institutions on FCA enforcement investigations, internal and whistleblowing investigations. She routinely advises on the SMCR, the FCA and PRA Code of Conduct and fitness and propriety issues.Chantal has advised financial institutions in connection with a range of issues...

James Chadwick

Partner and Head of Financial Regulation and Disputes Group, TLT

James specialises in financial services litigation and contentious financial regulation. He is recognised as a leader in the field in The Legal 500 and widely regarded by his clients as the premier financial services litigation, contentious regulatory and investigations lawyer in the northwest. He is now the national Practice Group Head of TLT’s Financial Regulation and Disputes Group. Described as “fast becoming the go-to banking litigation partner in the UK, not just the North”, James specialises in financial services litigation and contentious financial regulation. He was shortlisted as Dispute Resolution Lawyer of the Year at The Legal 500 Northern Powerhouse Awards 2025. He has extensive banking experience and has advised some of the most high-profile UK regulated firms on key issues affecting their portfolios including the implementation of the Consumer Duty (for which James is TLT’s Consumer Duty Champion), crisis response to widely...

Web page updated on 21/05/2026

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