1. Senior management commitment
Whistleblowing (confidential reporting)
What it means to blow the whistle, what confidential reporting is and what is required to implement a system.
This article is written to meet the following sections of the Standards:
BRCGS Food Safety Issue 8 | 1.1.6 Confidential reporting system |
BRCGS Packaging Issue 6 | Not applicable |
BRCGS Agents & Brokers Issue 3 | Not applicable |
BRCGS Storage & Distribution Issue 4 | 1.1.6 Confidential reporting system |
FSSC22000 Version 5.1 | Not applicable |
IFS Food Version 7 | Not applicable |
SQF Edition 9 | Not applicable |

Contents
- The requirements
- Your solutions for whistleblowing compliance.
- What’s the difference between whistleblowing and confidential reporting?
- Introduction
- What does the BRCGS mean by ‘confidential reporting system’?
- What does the term ‘whistleblowing’ mean?
- What is the definition of a wrongdoing?
- Is whistleblowing a grievance?
The requirements
The business must have a whistleblowing system, so staff can report concerns.
If the business already has a whistleblowing system in place which has been established by brand owners or retailers, the business must still have its own system – to make sure that all products processed by the site, are covered by the system.
Staff must be made aware of the system and how to report their concerns, including those relating to product safety, authenticity, quality and legality.
There must be a process in place for senior management to assess any concerns that are raised.
Records of the assessment and any actions taken need to be documented and retained.
Your solutions for whistleblowing compliance
We have everything you need for whistleblowing compliance to BRCGS, choose from:
- Senior management commitment eDocs (which include whistleblowing).
- Whistleblowing mini training.
- Senior management commitment super course (which includes whistleblowing).
We would recommend the eDocs and the super course – then you’ve got everything you need to comply with section 1 (including whistleblowing) with ease!
What’s the difference between whistleblowing and confidential reporting? Â
Confidential reporting is a term used by BRCGS but it means the same thing as whistleblowing. The regulations and laws around the world calls it whistleblowing – so we would recommend you do too. The whistleblowing mini training teaches you the requirements for BRCGS confidential reporting and also how to comply with the whistleblowing laws.
Introduction
The business must have a confidential reporting system so that staff can report concerns relating to product safety, authenticity, quality and legality.
Even if the business already has a whistleblowing system in place that’s been established by brand owners or retailers, the business must still have its own system – to make sure that all products processed by the site are covered.
Staff must know how to report their concerns, e.g. using a phone number.
Once a concern has been reported, there must be a set process for senior management to use. Records of this assessment and any actions taken need to be documented and retained.
What does the BRCGS mean by a ‘confidential reporting system’?
A confidential reporting system is the same as a whistleblowing system. There’s a law on whistleblowing in the UK – the Employment Rights Act 1996 (as amended by the Public Interest Disclosure Act 1998). This law defines what whistleblowing is.
What does the term ‘whistleblowing’ mean?
“Whistleblowing is making a disclosure. Basically, it’s telling someone about a wrongdoing, which most of the time happens at work. The law states, that the person blowing the whistle, by law, must believe two things:Â
- That they’re acting in the best interests of the general public.Â
- That the wrongdoing conforms to the definition, as set out by the law.Â
To understand this properly, you need to understand what a wrongdoing is.“
This is an extract from the whistleblowing mini training, which teaches you what the law says, what the requirements of BRCGS are, what it all means and most importantly – how to implement it.Â
What is the definition of a wrongdoing?
A wrongdoing is something that’s happened in the past, is currently happening, or they feel is likely to occur in the future, such as:
- A criminal offence (this may include, for example, types of financial impropriety such as fraud).
- Failure to comply with an obligation set out in law.
- A miscarriage of justice.
- That someone’s health and safety is in danger.
- Damage to the environment.
- Or, covering up wrongdoing described.
The whistleblowing law protects the individual that’s blown the whistle and gives them the right to take the case to tribunal if they feel they’ve been victimised at work, because of it.
The UK Government has provided a guidance document for businesses who wish to implement a whistleblowing system. You can find the document here: Government guidance document
Is whistleblowing a grievance?
No – whistleblowing is different from reporting a grievance.Â
A grievance is a wrongdoing from one person to another. A wrongdoing as defined by the whistleblowing law – has to be a wrongdoing against the public, not against one person.Â
The whistleblowing mini training teaches you everything you need to know – to implement a good whistleblowing system and communicate it out to all your staff, so that they understand when to use the whistleblowing system and when to use the grievance system.
Your next steps
To make your life as simple as possible, we would recommend you complete the senior management commitment super course and use the senior management commitment eDocs. The eLearning and eDocs contain everything you need to comply with BRCGS section 1 for senior management commitment, including whistleblowing.
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