Thematic review on Whistleblowing

The Riffle

The DFSA found that around 40% of the respondents had gaps in policies and governance mechanisms related to whistleblowing. Time to review your Whistleblowing policy!

The DFSA's 2025 Whistleblowing Thematic Review found that while most regulated entities have whistleblowing policies, many lack effective measures to protect whistleblowers and monitor for retaliation.

The review also identified issues with the quality of policies and procedures, particularly in addressing DFSA guidance. Additionally, nearly half of the sampled entities had inadequate governance arrangements for whistleblowing oversight.

Key action items:

1. Enhance Whistleblower Protection: Ensure policies include robust measures to protect whistleblowers' identity and confidentiality, safeguard them from retaliation, and monitor for any detriment suffered due to reporting.

2. Improve Policies and Procedures: Regularly review and update whistleblowing policies to align with DFSA guidance, clearly define "regulatory concerns," and include procedures for reporting, assessing, and escalating concerns.

3. Strengthen Governance: Establish governance arrangements to provide senior management with comprehensive whistleblowing reports, including case details, trends, and outcomes, while ensuring restricted access to sensitive information.

4. Promote Speak-Up Culture: Foster a culture that encourages open communication by embedding whistleblowing arrangements within corporate practices and conducting employee surveys to assess trust in the system.

5. Address Gaps in Group Policies: Ensure local entities relying on group whistleblowing policies adapt them to meet DIFC-specific legal and regulatory requirements.

6. Provide Feedback Mechanisms: Incorporate steps to offer feedback to whistleblowers where feasible and manage conflicts of interest fairly.

7. Monitor Retaliation Risks: Introduce mechanisms like assigning support contacts or hotlines for whistleblowers to report retaliation incidents and track such cases independently.

8. Conduct Root Cause Analysis: Investigate issues raised in reports, address deficiencies in policies or procedures promptly, and take remedial action as necessary.

Read the complete Thematic review here.

Here is our brief on the subject: