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Free form template · Word

Whistleblower Investigation Form

A whistleblower investigation form is the vigilance officer's working document for handling a protected disclosure. It assesses whether the disclosure falls under the policy, records identity-protection steps, defines the investigator's mandate, plans evidence collection, and summarises findings for the audit committee.

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[Company Logo][Company Name]

WHISTLEBLOWER INVESTIGATION FORM

Disclosure Code:
[Reference Number]
Date Received:
[Date]
Vigilance Officer:
[Name]
Classification:
Strictly Confidential

1. Preliminary Assessment

Summary of disclosure (without whistleblower identity)
Falls within vigil mechanism policy? (Yes/No, reason)
Seriousness: High / Medium / Low
Involves director or senior management? (if yes, inform Audit Committee Chair)
Decision: Investigate / Refer to another forum / Close (reason)

2. Identity Protection

  • Whistleblower identity stored separately and accessible only to the Vigilance Officer
  • Disclosure code used in all documents
  • Investigator briefed not to attempt to identify an anonymous whistleblower
  • Monitoring for victimisation arranged

3. Investigator Mandate

Investigator(s) name and organisation
Independence confirmed (Yes/No)
Scope of investigation
Target completion date

4. Evidence Plan

EvidenceCustodianPreservation StepDate Secured
[Accounts / ledgers][Finance][Read-only copy][DD/MM/YYYY]
[Emails][IT][Mailbox hold][DD/MM/YYYY]
[Vendor records][Procurement][Copy][DD/MM/YYYY]

5. Subject's Response

Subject informed of allegations on
Response received on
Summary of response

6. Findings and Recommendation

Findings on each allegation (substantiated / not substantiated / inconclusive)
Recommended action
Control or process improvements

7. Closure

Reported to Audit Committee on
Feedback given to whistleblower on
Case closed on
Investigator
[Name]
Date: [Date]
Vigilance Officer
[Name]
Date: [Date]

What this template includes

  • Preliminary assessment of scope and seriousness
  • Identity protection measures for the whistleblower
  • Investigator mandate and independence
  • Evidence collection and document preservation plan
  • Opportunity for the subject to respond
  • Findings and recommended action
  • Reporting to the audit committee and feedback to the whistleblower

When to use it

  • A protected disclosure has been received through the vigil mechanism
  • The vigilance officer must decide whether a disclosure warrants investigation
  • An external forensic auditor or internal audit team is appointed
  • The audit committee needs a status and findings summary

How to customise this template

  1. 1Assign a disclosure code instead of using the whistleblower's name
  2. 2Add forensic, legal or IT experts in the investigator section where needed
  3. 3Insert your audit committee reporting frequency
  4. 4Include data-preservation instructions for IT
  5. 5Keep this form apart from HR personnel files

HR tips

  • Preserve documents and data quietly before alerting the subject
  • The subject must still get a fair chance to respond to allegations
  • Use 'no evidence found' rather than 'false' unless malice is proved
  • Give the whistleblower general feedback without disclosing confidential details

This template is a starting point. Review it against company law vigil mechanism requirements, listing rules where applicable, your whistleblower policy and with legal or forensic advisers.

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Frequently asked questions

Who investigates a whistleblower complaint?+

The vigilance officer, or an investigator appointed by them or the audit committee, who must be independent of the people involved.

Is the subject of a whistleblower complaint told about it?+

Yes, at an appropriate stage. They must be informed of the allegations and given an opportunity to respond, usually after key evidence is preserved.

What feedback does the whistleblower get?+

Usually a confirmation that the matter was examined and closed, without sharing confidential findings or action against others.