How to be a whistleblower and live to tell the tale

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AAT members may find themselves the only qualified person in an organisation speaking truth to power. So how’s it done?

Blowing the whistle is always a big step, and it’s not without its risks. Of course, doing so can be daunting. Any claim must be well evidenced and won’t be made lightly, but accountants, AAT members included, have a duty to sound the alarm when they encounter wrongdoing. 

Between April 2021 and March 2022, the Financial Conduct Authority (FCA) received 1,041 reports; in 2020-21 the Financial Reporting Council (FRC) saw a seven-fold increase on the previous year and HMRC saw a rise of more than 50%. This might portray an established and accessible reporting system that encourages people concerned about wrongdoing to come forward, but underlying figures tell a slightly different story. 

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By April 2022, the FCA was still considering 801 cases (77%) of the previous year’s 1,041 reported cases and had only acted in 9.5% of them. It was also reported that some cases are having to wait for over a month to pass to the right team.  

Meanwhile, the FRC said that 53 of the 67 disclosures it received in 2020-21 were outside its remit and were passed to other regulators, and HMRC has given little insight into the actions it took on the influx of reports it received, many related to Covid-19 furlough scheme fraud. 

Such a mixed picture is not encouraging for potential whistleblowers. As an act, it is never one undertaken lightly. People risk careers and relationships, and their financial and mental wellbeing. 

And while reporting wrongdoing is encouraged by the Government and an obligation under AAT’s code of ethics, many are guided first by a strong moral compass, which makes doing or saying nothing harder to live with than the act of whistleblowing. 

This was the case for new AAT president Christina Earls, whose tenure will include a focus on helping students develop a personal ethical code. 

“Ethics is not a boring, dry subject,” she says. “AAT members may find themselves the only qualified person in an organisation speaking truth to power.” 

This was a situation Earls found herself in towards the end of her career in the civil service. She sought to call out misallocation of funds, but ultimately her pleas fell on deaf ears. Her organisation’s whistleblowing policy was not followed, her anonymity was not protected and her working life deteriorated. 

She did all the right things, but this was not reciprocated by leadership, an experience that unfortunately highlights the personal risks involved – victimisation and bullying, career limitations, impacted mental and physical wellbeing – and the precariousness that faces potential whistleblowers in the UK. 

So, whistleblowing is something to do with your eyes wide open.

Trigger points 

  • Money laundering
  • Tax fraud and evasion
  • Wrongdoing at a financial services firm
  • Mis-selling and mispricing
  • Accounting fraud, such as illegally altering a company’s financial statements, overstating revenue or failing to record expenses, and misstating assets and liabilities

When to raise the alarm

A concern should be reported as soon as possible after witnessing or becoming aware of any wrongdoing, risk or malpractice at work.  

Blowing the whistle must always be in the public interest – for example, reporting furlough scheme fraud, tax evasion or people’s safety being in danger – and not based on personal grievances. You can report a past event, one that’s happening now, or that you suspect will happen.  

There is no whistleblower act in the UK, but people are protected by law under the Employment Rights Act 1998, which means you can take a case to an employment tribunal if you’ve been treated unfairly, including being victimised at work or dismissed for whistleblowing. 

How to make your complaint

It’s best to make a claim in writing, firstly for clarity, secondly for your own protection and thirdly so there’s a ‘paper trail’. 

Indeed, keep a record of everything, says Earls. “I’ve got a history of good governance in local government. There were many times in my career where people wanted me to say nothing. I learned very early on that you must back-up emails. If people only want to talk with you in person, make sure it’s recorded, otherwise it becomes ‘he said, she said’. Write everything down, especially if you feel bullied.” 

Earls also suggests surrounding yourself with like-minded people and a network you can lean on. “I leant on my CIPFA network, who gave lots of informal advice, which is what kept me going, because I knew I was right. I’ve got to sleep at night and I knew I would do exactly the same in the same situation.” 

Make a telling disclosure 

The better the disclosure, the more quickly and efficiently it can progress, which can involve talking to relevant people, seeking evidence, and pulling together corroborating data and documents. 

People are strongly advised not to proactively obtain any further information or to investigate, as this might break the law. Focus on facts, not opinions. For example, this would make a decent initial disclosure template: 

  • the firm or individual’s name
  • what is the suspected wrongdoing
  • who is involved
  • how long it has been going on
  • where this is happening
  • what the impact is
  • if you have any supporting documents or evidence you can share

Who to tell 

Before heading directly to a regulator with a disclosure, Andrew Pepper-Parsons, head of policy at whistleblowing charity Protect, recommends reading your employer’s whistleblowing policy, which is increasingly common, though not legally required in all sectors, such as it is in the NHS. 

If your employer doesn’t have a whistleblowing policy, you can seek advice from the Advisory, Conciliation and Arbitration Service (Acas), Citizens’ Advice, the whistleblowing charity Protect (which AAT works with on its Anti-Money Laundering (AML) Whistleblowing Policy) or your trade union. You can also go to a professional body, including AAT. 

Earls found her union was very useful. “They were familiar with my background. I know some people think it’s political, but I have always advocated being in a union, because they will work for you, even if you don’t know them, and you need allies.” 

Approaching your employer, while not always possible, is advised in the first instance before escalating to a regulator. Pepper-Parsons recommends going to someone senior, unrelated to the concern. And while HR might seem an obvious first stop, Earls thinks that beyond telling you where the whistleblowing policy is, they’re not always capable of providing support. 

Unfair treatment 

Pepper-Parsons points out that while you cannot completely eradicate risk from being a whistleblower, most people who report concerns do not suffer unfair treatment and most are not victimised by their employers, managers or colleagues. 

However, if you do suffer victimisation and unfair dismissal, you can take your case to an employment tribunal. 

Whistleblowing legislation protection in the UK can cover the following treatment of whistleblowers who disclosed information in the correct way: 

  •  dismissal
  • disciplinary action
  • threats
  • being overlooked for promotion
  • unfairly receiving a poor performance review
  • not receiving a bonus or benefits
  • being excluded or isolated


According to employment law firm BDBF: “You are entitled to claim uncapped compensation for the losses caused by the detrimental treatment you have suffered. However, you will be under a duty to mitigate your losses by taking reasonable steps to find a new job. Your losses may include loss of salary, bonus, shares, options, benefits, pension, and the hurt, distress, and any personal injury caused.” 

AAT contacts and resources 

Helpline: 0207 367 3182
Email: [email protected]
AAT’s recently updated AML Whistleblowing Policy:

Neil Johnson is a freelance business journalist who contributes regularly to trade publications and member organisations, covering employability, recruitment, business trends and industrial analysis.

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