Setting up a reporting channel: a checklist for companies
This page is not legal advice.
Use this checklist when introducing an internal reporting channel. Each step names the section of Act 1171/2022 it comes from. It is general information, not legal advice.
- 1. Check whether you are obliged (section 10): regularly at least 50 persons, or a supplementary pension institution. Smaller organisations may run a voluntary channel (section 13).
- 2. Choose the model: your own channel or an outsourced operator (section 11). You remain responsible for the duties either way.
- 3. Designate impartial handlers and deputies (section 14). Only they may process reports.
- 4. Decide whether you accept anonymous reports (section 17), and write the decision into your published information.
- 5. Offer written reporting, and decide whether you also offer oral reporting. If you do, it must work by phone or another voice-message system, with a face-to-face meeting on request within a reasonable time (section 15).
- 6. Plan the deadlines: acknowledgement within seven days (section 15) and feedback within three months (section 16). Decide who watches them during holidays.
- 7. Keep identities and reports confidential (section 32): limit access to the designated handlers. A log of who did what helps you show it.
- 8. Set retention: report data is erased five years after receipt unless further retention is necessary for statutory rights, obligations or legal claims (section 29). Clearly irrelevant personal data goes without undue delay.
- 9. Publish clear information on internal reporting, the Chancellor of Justice’s external channel, the procedures and the conditions of protection (section 15): intranet, induction material, notice boards and your website.
- 10. Test the channel end to end before launch: submit a test report, acknowledge it, reply, and check that the reporter can read the reply.
Step 1 in two minutes: take the self-check.
Ilmoo’s product pages explain which of these steps the software supports. The organisation’s own decisions, such as who handles reports, remain yours.