Should Whistleblowing be added as a new policy to employee handbooks or as an addition to, for example, our Data Protection policy?

The whistleblowing legislation imposes no positive obligations on employers to encourage whistleblowing or to implement a whistleblowing policy. It merely requires them to refrain from dismissing workers because they have made a "protected disclosure" or subjecting them to any other detriment because of it. However, there are good business reasons why employers (other than, perhaps, those with only a small handful of employees) should have a written policy on whistleblowing. Namely, to:

• Encourage a culture where concerns are reported internally at an early stage, making it easier for management to address those concerns and therefore avoid more serious regulatory breaches or reputational