A Content Analysis of Organizations’ Internal Whistleblowing Policies

56 Pages Posted: 29 Mar 2019

See all articles by Lei Gao

Lei Gao

University of Akron - The George W. Daverio School of Accountancy

Alisa Gabrielle Brink

Virginia Commonwealth University

Date Written: March 5, 2019


Section 406 of the Sarbanes Oxley Act (SOX) requires that U.S. public firms disclose their adoption of a code of ethics that includes formal whistleblowing procedures. Public companies listed on NYSE or NASDAQ are also required to prepare this disclosure. Formal whistleblowing policies guide employees through the ethical decision-making process and promote reporting unethical behaviors. Authoritative bodies have prescribed whistleblowing guidelines, such as the Council of Europe Resolution 1729 (COER) and the International Chamber of Commerce (ICC) Guidelines on Whistleblowing. However, there is no conclusive evidence of the effectiveness of firms’ whistleblowing policies on reporting behavior, and prior research calls for further investigations into the design and implementation of effective internal whistleblowing policies. Through a whistleblowing procedures framework, we performed a content analysis of 50 whistleblowing policies to analyze the content characteristics and linguistic characteristics of public firms’ whistleblowing policies. Results of this study identify trends and patterns within whistleblowing policies. Key findings include that firms prefer employees to report to their supervisor. However, there is little discussion of supervisors’ responsibilities after receiving reports. Also, the use of words expressing uncertainty is highest when companies describe disciplinary actions in response to wrongdoing. Further, readability analysis suggests that companies’ whistleblowing policies are difficult to read, and sections relating to investigation procedures, wrongdoer disciplinary actions, and anti-retaliation policies are relatively more difficult to read than the rest of the policy content. We discuss implications for firms with the aim of improving the effectiveness of stated whistleblowing procedures.

Keywords: whistleblowing policy, anti-retaliation policy, content analysis, readability, language uncertainty

Suggested Citation

Gao, Lei and Brink, Alisa Gabrielle, A Content Analysis of Organizations’ Internal Whistleblowing Policies (March 5, 2019). Available at SSRN: https://ssrn.com/abstract=3347181 or http://dx.doi.org/10.2139/ssrn.3347181

Lei Gao (Contact Author)

University of Akron - The George W. Daverio School of Accountancy ( email )

United States

Alisa Gabrielle Brink

Virginia Commonwealth University ( email )

301 W. Main St.
PO Box 844000
Richmond, VA 23284
United States

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