As ethical business practices become more critical in hospitality, having a whistleblower policy is a smart move to ensure hotel industry staff do the right thing at every turn. A whistleblower is an individual who discloses information about a past, an ongoing or a premonitory malpractice in an organisation. Whistleblowing is an effective way of revealing internal wrongdoings before damage spreads within and beyond the business. A whistleblowing policy demonstrates managements' commitment to transparency. 

In this article, dive into the nitty-gritty of whistleblowing and get access to a 9-step guide to help you develop a whistleblowing policy for your hotel/restaurant.


What Is a Whistleblowing Policy?

A whistleblowing policy is an official document that aims to create a safe space for hospitality employees to report unethical and/or illegal practices happening in the workplace. A company-wide whistleblower policy sends a strong message that ethical breaches are forbidden, and employees are at liberty to report wrongdoings to management. Here are the key components of a good whistleblower policy:

  • Impartiality: A good whistleblower policy guarantees disclosures will be handled fairly. Impartiality instils confidence in the process, and encourages whistleblowers to come forward.
  • Awareness: You need to publicise the policy across the organisation to make employees aware of their rights and duties in reporting. The policy should also be part of the onboarding process for new hires.
  • Compliance: Ensure your policy is compliant with the relevant legal provisions of the jurisdiction the business is operating from. For instance, if you're operating a hotel/restaurant in Spain, France or Italy, the policy needs to comply with the EU Whistleblowing Directive.[1]
  • Consistency:  It’s important that all disclosures are handled with equal sensitivity and respect. Once a report has been received, hotels should move with speed to investigate the claim and take the necessary measures.
  • Protection: Where whistleblowers may be required to provide further disclosures or remove their anonymity cover, essential safeguards need to be in place. A whistleblower policy that falls short on protection might not serve the intended purpose because of fear of reprisal.

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Who Is a Whistleblower?

A whistleblower is anyone who comes forward with information about illegal or unethical activities in an organisation. Whistleblowers can be internal, such as employees and interns or external such as suppliers, contractors, and customers. Typically, a whistleblower is not required to investigate the issue or determine corrective measures. A whistleblowers' role ends at reporting. However, they may be called to provide more information at the investigative stage.


Who is an Ombudsman?

An ombudsman is an independent third-party who helps resolve conflicts between individuals and organisations. Ombudsmen are well-versed in organisational dynamics and conflict management, which enables them to pinpoint causes of disputes and suggest workable solutions. The organisation which is subject to a complaint typically hires an ombudsman. However, the ombudsman does not represent or advance the interest of the organisation as would an attorney, a mediator, or a human resource representative.

What an Ombudsman Does 

An ombudsman assists a company’s management to handle difficult issues in a confidential and impartial manner. The ombudsman provides employees with a safe haven for them to air their concerns without fear of reprisals. They also act as a sounding board for the management to identify systemic issues affecting the work environment. An ombudsman’s recommendations can be used to create or update a workplace policy. Bringing an ombudsman on board can help hospitality businesses forestall industrial actions, litigation, and reputation damage.



Which Scenarios Qualify for Whistleblowing?

The range of scenarios which qualify for whistleblowing vary from one company or country to another. For instance, in the UK, the law allows for whistleblowing only in the public interest. Personal grievances such as discrimination and bullying are not subject to whistleblowing.[2]

Here are typical scenarios that can qualify for whistleblowing in the hotel sector:

  • Employee theft
  • Dishonest cleaning practices
  • Providing inferior supplies
  • Hotel espionage
  • Questionable accounting or auditing practices
  • Disclosure matters
  • Internal controls lapses or override
  • Insider trading
  • Conflicts of interest
  • Serious breaches of group policy
  • Collusion with competitors
  • Unsafe work practices
  • Fraud and corruption
  • Suspected criminal offence
  • Breach of a legal obligation
  • Endangering the health and safety of any individual
  • Damage to the environment
  • A deliberate attempt to cover up any one of the above

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Why Your Hotel Business Needs a Whistleblower Policy

A whistleblower policy is a mandatory requirement in most jurisdictions. In the EU, for instance, businesses with at least 50 employees are required to have internal whistleblowing reporting channels. Here are reasons travel and leisure businesses need this policy: 

  • Encourages transparency: A whistleblowing policy demonstrates to employees that the management takes transparency seriously. The policy sends a strong message that ethical conduct is valued and whoever blows the whistle on wrongdoings will be protected.
  • Sets reporting standards: A policy on whistleblowing details what a whistleblower needs to do to report wrongdoings. The policy outlines the channels to use, where to report, and what to expect after reporting.
  • Outlines investigation procedure: A whistleblowing policy contains the steps to be undertaken when investigating a reported breach. This ensures consistent application of the policy.
  • Prevents financial losses and reputational damage: A whistleblowing policy can help an organisation take corrective timely corrective measures. This can save the company from bad press, public lynching, regulatory sanctions, costly lawsuits and employee disengagement.
  • Reinforces accountability: Whistleblowing illegal or unethical practices ensures people or departments responsible for the breach are held to account. 

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[1] The EU Whistleblowing Directive,

[2] Whistleblowing for employees,