Whistleblowing Channel: Perception of the Mechanism’s Effectiveness for Business Integrity

Almir Ribas dos Santos; Murilo Cesar Merloto

DOI: 10.22167/2675-6528-202602626

Article derived from a Course Conclusion Work (TCC), with content based on the student’s original work and adapted to the editorial format of the E&S Magazine with the support of the ResumeAI tool, an artificial intelligence solution developed by Instituto Pecege for textual synthesis and organization.

Summary

The constantly evolving regulatory market landscape and the need for compliance structures have driven the relevance of whistleblowing channels. The reliability and effectiveness of these channels as a tool to strengthen corporate integrity were assessed. To this end, a remote survey was conducted using the Google Forms platform, collecting perceptions from 74 employees of various organizations. The questions addressed everything from the existence and disclosure of the channel to the reliability of investigative management and suggestions for improvement. The results indicated that whistleblowing channels are widely disseminated, with training as the main means of disclosure and a high rate of anonymity (85%) as a good practice. The prevalence of moral harassment reports was observed. However, a critical finding revealed that 34% of participants did not feel safe using the channel, highlighting the persistence of a “culture of silence” and challenges in building trust, especially regarding impartiality in investigations and the guarantee of non-retaliation. Despite this, 86% of the public perceived the channel as an integrity instrument. It was concluded that the implementation of whistleblowing channels is a necessary but insufficient step on its own, making it essential to build trust in the impartiality of the investigative process and the guarantee of non-retaliation for the effective establishment of corporate integrity.

Keywords: Whistleblowing channel; Compliance; Ethics; Integrity.

1. Introduction

The contemporary business scenario is characterized by constant regulatory evolution that directly impacts the evaluation and operations of companies. In this context, the perennial construction of compliance structures becomes imperative, requiring organizational practice to consistently reflect the discourse of integrity. In Brazil, Law 12.846/2013, known as the Anti-Corruption Law, brought a relevant improvement by objectively holding legal entities liable for acts of corruption, transcending the fault of their administrators and representatives (Brazil, 2013; Frazão, 2015). Additionally, Law 14.133/21, the Law on Bidding and Contracts, established the Compliance or Integrity Program as a fundamental instrument for fostering an ethical environment in organizations (Brazil, 2021).

Corporate integrity is an essential pillar, supported by a Compliance Program that integrates practical mechanisms, such as policies, codes of ethics, and whistleblowing channels. These elements are crucial for preventing misconduct and ensuring that all employees are aligned with the company’s values. Corporate governance is the foundation for the sustainable growth of organizations, requiring leadership to incorporate ethical, social, and environmental perspectives into their business strategies (Silva, 2016). Senior management must, therefore, be the practical example of ethical prioritization, reinforcing that corporate integrity is a prevalence in the organization, as leadership engagement is fundamental to the solidity of the compliance management system (Maeda, 2013; Assi, 2018).

In this context, the whistleblowing channel constitutes a vital instrument for maintaining institutional integrity and repressing illicit acts. Its implementation can occur through corporate portals, emails, phones, or social media. The management of these channels, often outsourced to reinforce the guarantee of protection for the reporter, known as a “whistleblower”, must ensure confidentiality and anonymity (Scandelari, 2024). To be effective, the investigation process requires secrecy of information, protection of the whistleblower’s identity, and a guarantee of non-retaliation, lending credibility to the mechanism (Marconi, 2021). The Comptroller General of the Union (CGU, 2015) and Decree 6029/2007 (Brazil, 2007) emphasize the importance of in-depth investigations and protection against retaliation, warning that the absence of investigation demoralizes the ethical culture.

Despite the theoretical and regulatory relevance, the effectiveness of reporting channels is often compromised in practice. Employees sometimes opt to contact external regulatory bodies instead of internal resources, motivated by fear of retaliation, dismissal, or career stagnation. This evasion occurs because the channel is, in many cases, perceived as a mere complaint collector, without effective support for the whistleblower or the reported issue (Kastiel, 2014). The “KPMG 2024 Brazil Harassment Map Survey” revealed that 30% of professionals have experienced harassment, with 46% reporting moral harassment, and an alarming 92% of victims do not report it, justified by fear of retaliation and disbelief in the effectiveness of internal channels (KPMG, 2024a). The persistence of a “culture of silence,” where 34% of the public states they do not feel safe using the channel, points to the challenge of building trust in the impartiality of investigations and the guarantee of non-retaliation.

Although reporting channels are widely disseminated in organizations and research on the topic exists, such as the “11th National Survey of Reporting Channels” by Be.Aliant (2026), which identifies patterns that weaken these mechanisms, many of these analyses tend to have a commercial bias. They often do not delve into users’ perceptions of trust, impartiality, or reasons for non-use, offering little information on applicable improvements. There is, therefore, a gap in the in-depth understanding of employees’ perceptions of the reliability and effectiveness of these channels, which goes beyond formal indicators of existence and use.

Given this scenario, the present research is justified by the need to go beyond the mere formal existence of channels, seeking to understand the users’ perspective to strengthen business integrity. The objective of this study was to collect, through a questionnaire, the perception of collaborators from public and private organizations regarding the reliability and understanding of the effectiveness of reporting channels as an instrument for strengthening business integrity.

2. Material and Methods

The present research was characterized as exploratory, with a methodological approach of field survey. This type of study was selected to deepen the understanding of employees’ perception regarding the effectiveness of reporting channels, aligning with the objective of collecting data on the reliability and understanding of the effectiveness of these mechanisms as instruments for strengthening corporate integrity. The research strategy involved the application of an online questionnaire, aiming to reach a diverse audience efficiently.

The unit of analysis consisted of the perception of collaborators from public and private organizations. Participants were selected for being professionals linked to the theme and active in medium and large companies, predominantly from the private sector. Data collection was carried out remotely, using the Google Forms platform, the link of which was widely distributed through the WhatsApp application, facilitating access and participation of respondents.

The data collection instrument was a semi-structured questionnaire, composed of 17 questions. The questions were of a structured nature, including dichotomous options and considered neutral alternatives, designed to capture the diverse perspectives of the participants. The questionnaire was organized into three distinct thematic blocks, seeking a comprehensive approach to the subject.

The first block of the questionnaire focused on investigating respondents’ knowledge about the existence of the whistleblowing channel in their respective organizations and how this tool is internally disseminated. The second block explored participants’ perception of impartiality and ethics in conducting whistleblowing investigations. Finally, the third block sought to collect opinions on management models that could optimize the channel’s effectiveness.

Data collection occurred between December 11, 2025, and January 18, 2026. Initially, the goal was to compile at least 20 answered questionnaires. However, the survey exceeded this expectation, reaching a total of 74 respondents, who generated 1,258 individual responses (META, 2026). This number of participants allowed for a more robust view of the topics addressed.

For the analysis of the collected data, a descriptive technique was employed, focused on the organization and summarization of employee perceptions. The raw data, obtained through the questionnaire, were compiled and categorized to identify patterns and trends in the responses. This approach allowed for a clear understanding of the opinions expressed, without delving into inferential statistical analyses or complex interpretations.

Additionally, to contextualize the study, a review of reports and metrics was conducted for three companies that offer technological solutions and serve organizations with integrity programs. These documents, often published as yearbooks, provide indicators about the compliance market, albeit with a commercial bias. This stage served to support the discussion about the gap in in-depth information regarding user perception.

Ethical considerations were rigorously observed throughout the research process. Participant collaboration was voluntary and anonymous, with no obligation to answer all questions. It was ensured that there would be no payment or disbursement by participants, and anonymity was guaranteed, with responses being used exclusively for the purposes of this study, as explained in the consent form present in the Appendix.

3. Results and Discussion

The initial analysis of the market context and integrity scenario, conducted through the review of reports and metrics from three companies offering technological solutions for whistleblowing channels, revealed a significant gap. It was observed that the yearbooks and documents from these companies, while presenting indicators on segments and types of reports, often carry a commercial bias. Such sources do not deepen users’ perception of trust, impartiality, or the reasons for not using the channels, nor do they provide statistical data on the absence of disclosure or the effectiveness of investigative management. This finding reinforced the need for more in-depth research, focused on the perspective of collaborators.

To fill this gap, the field research was conducted remotely, using the Google Forms platform, with the link distributed via WhatsApp, between December 11, 2025, and January 18, 2026. The survey reached 74 respondents, totaling 1,258 answers, a number higher than predicted in the methodology. This expanded reach allowed for a more robust view on sensitive topics related to corporate behaviors, where obtaining reliable information on employee perception is a significant challenge, especially in smaller samples. The majority of participants, 97%, belonged to organizations in the private sector, while 3% worked in the public sector.

The initial research findings indicated that the existence of reporting channels is widely recognized in organizations. It was found that 88% of employees confirmed awareness of the communication instrument in their companies. Regarding the dissemination of these channels, training provided by organizations was pointed out as the main channel, mentioned by 69% of respondents. Other relevant channels included managers and colleagues, with 42% of mentions, intranet, with 41%, and the organization’s website, with 39% recognition. Only 9% were unaware of the channel and 3% indicated it was not disclosed.

The possibility of anonymous reporting of complaints was a well-evaluated aspect by the participants. It was found that 85% of respondents stated that identification is not required in the channels provided in their organizations. This data is an indication that most companies follow the guidelines recommended by the Comptroller General of the Union (CGU, 2015) in its Integrity Program Implementation Guide, which emphasizes the importance of anonymity to encourage reporting. However, 11% were unaware of this possibility and 4% indicated that anonymity was not permitted.

Despite the widespread dissemination and the possibility of anonymity, the effective use of reporting channels still presents challenges. The survey revealed that only 16% of collaborators who had access to a reporting channel in their organization had ever used it. The vast majority, 82%, had never used the channel, and 8% were unaware of it. Among the reported cases, the most frequent themes were moral harassment and sexual harassment, both with 7% of occurrences. Fraud and theft accounted for 5% of reports, while self-dealing or favoritism for others amounted to 4% each. Corruption and undue relationships with suppliers were cited by 3% of users, and discrimination by 1%.

The prevalence of reports of moral and sexual harassment corroborates findings from other research, such as the “KPMG’s 2024 Map of Harassment in Brazil Survey” (KPMG, 2024a), which also identified moral harassment as a significant occurrence in the workplace. This scenario reinforces the urgency of continuous and effective actions by organizations to promote a safe and ethical work environment. The low utilization rate of the channel, even in the face of problems such as harassment, suggests that the mere availability of the tool is not sufficient to guarantee its full effectiveness.

A critical finding of the research was the perception of security in using the channel. It was found that 34% of the public who have a reporting channel available do not feel safe using it. This data is alarming and points to the persistence of a “culture of silence” in organizations, even with the formal existence of channels. Only 58% of respondents felt safe, and 8% were unaware of the channel. This distrust converges with Be.Aliant’s “11th National Survey of Reporting Channels” (2026), which indicated a drop in the degree of trust in using the channel between 2024 and 2025, from 69.3% to 58.9% in the maximum satisfaction score.

Employee insecurity can be attributed to several factors, as pointed out by Kastiel (2014), including negative experiences, unmet expectations, lack of adequate feedback, and the absence of disclosure about channel success stories, even if anonymized. The lack of transparency regarding the investigation flow and disciplinary measures applied also contributes to this distrust. The survey revealed that 45% of participants are unaware of the steps involved in investigating a complaint, and 36% believe there is no agility or effectiveness in handling reports addressed to the channel.

The lack of clarity regarding investigative processes and the application of disciplinary measures is a factor that distances the public from reporting channels. It was identified that 51% of respondents are unaware of the disciplinary measures applied after the investigation of a complaint. According to Nascimento (2024), an effective reporting channel must have defined response flows and deadlines, operating with transparency and impartiality. The recommendation by Hencsey, Bezerra, and Peres (2020) for the creation of internal regulations or protocols in structuring the investigations area is fundamental to standardize procedures and ensure that each report is handled consistently, increasing the perceived security by users.

The perception of impartiality in the actions taken by the company after the registration of complaints also proved to be a critical point. It was found that 35% of respondents expressed not finding impartiality in the handling of the complaints received and investigated. This perceived lack of impartiality can compromise the credibility of the channel and discourage future complaints. Top management, as emphasized by Maeda (2013) and Assi (2018), must be the practical example of ethical prioritization, ensuring that integrity principles are demonstrated in practice and that the position of the accused is not a factor in mitigating penalties or camouflaging irregularities.

When asked about measures that could make the channel more efficient, 62% of respondents indicated the need for equitable treatment of complaints, regardless of the position of those involved. Other relevant suggestions included the application of more effective training (50%), greater dissemination of results regarding the channel (41%), communication from the organization’s CEO demonstrating commitment to integrity (39%), and outsourcing the channel to a specialized company (39%). Agility in handling received cases was mentioned by 35% of participants.

The outsourcing of the channel, according to Scandelari (2024), can reinforce the guarantee of confidentiality, anonymity, and protection of the reporter’s data, contributing to effectiveness. The balance between the duty of secrecy and the need for accountability lies in the statistical consolidation and depersonalization of published data. Organizations should report the “what” and the “how” of incidents, but never the specific “who” or “where”, especially in smaller structures. Public reports should focus on metrics such as volume of communications, classification of incidents (harassment, fraud, discrimination), and resolution rate, validating the efficiency of the process without violating the pact of silence.

Despite the challenges and areas for improvement identified, the research revealed a generally positive perception of the role of whistleblowing channels. It was observed that 86% of the public believes that the channel is an instrument that strengthens ethics and integrity in the company. Additionally, 74% of respondents understand that the channel is effective in preventing irregularities. These data demonstrate that, even with gaps in trust and transparency, whistleblowing channels are perceived as valuable tools that add value to the organization and promote employee well-being, going beyond mere regulatory compliance.

Nevertheless, the research indicated that there is room to expand communications and training on the channel’s purpose. The sum of respondents who rarely receive communication or training (13%) and those who do not receive it (18%) totals 31% of the audience with insufficient communication. Constant reinforcement from senior management, as emphasized by Silva (2016), is crucial for enriching the integrity and governance program, creating conditions for a more rational and ethical company. Continuous evaluation of the integrity program should be a fixed and priority agenda item in leadership meetings, as compliance is an institutional duty that is operationalized through all employees.

In summary, the research results indicated that reporting channels are widely present in organizations and are perceived as essential instruments for corporate integrity and the prevention of irregularities. However, the effectiveness of these channels is compromised by the persistence of a “culture of silence,” evidenced by the insecurity of a significant portion of employees in using them and by the lack of knowledge about investigation processes and disciplinary measures. Building trust in impartiality, agility, and the guarantee of non-retaliation, along with transparent communication and the engagement of top leadership, are fundamental for these mechanisms to reach their full potential in strengthening corporate ethics.

4. Conclusion

The study sought to collect employees’ perceptions regarding the reliability and effectiveness of whistleblowing channels as an instrument for strengthening corporate integrity. It was found that whistleblowing channels are widely disseminated in organizations, with training being the primary means of communication and a high rate of anonymity permitted. Reports of moral and sexual harassment were observed. However, a critical finding revealed that a significant portion of participants did not feel safe using the channel, evidencing the persistence of a “culture of silence.” This insecurity was attributed to a lack of knowledge about the investigation steps, the perception of a lack of agility and effectiveness in handling reports, a lack of clarity regarding disciplinary measures applied, and the perception of impartiality in the actions taken. Despite these challenges, most employees perceived the channel as a valuable tool for strengthening ethics and integrity and preventing irregularities. The main contribution of this study lies in demonstrating that the mere implementation of whistleblowing channels is insufficient; it is crucial to build trust in the impartiality of the investigative process and in the guarantee of non-retaliation for the effective implementation of corporate integrity.

A limitation of the study stems from the predominance of respondents from the private sector, which may restrict the generalization of findings to public organizations. For future work, it is recommended to investigate the causes of employee insecurity, seeking to extract precise information about feedbacks received and to deepen the analysis of indicators from the perspective of the area responsible for investigations. Regulatory improvement is also suggested to include a qualitative approach, which allows crossing data from labor lawsuits with records in whistleblowing channels, and the requirement for greater transparency in the anonymized disclosure of results, potentially integrating the annual scope of internal audits or regulatory bodies. Additionally, a deeper dive into theses on the outsourcing of channels, comparing internal and external management structures, can offer valuable insights into the perception of security and absence of biases.

Bibliographic References

Brasil. 2013. Lei n. 12.846, de 1º de agosto de 2013. Dispõe sobre a responsabilização administrativa e civil de pessoas jurídicas pela prática de atos contra a administração pública, nacional ou estrangeira e dá outras providências. Diário Oficial da República Federativa do Brasil, Poder Executivo, Brasília, DF, 02 ago. 2013. Seção 1, p. 1.

Brasil. 2021. Lei n. 14.133, de 1º de abril de 2021. Nova Lei de Licitações e Contratos Administrativos. Diário Oficial da União, Brasília, DF, 01 abr. 2021. Seção 1 – Extra F. p.1.

Frazão, Ana. Implementação de programa de compliance deve atenuar penalidades a empresas. Consultor Jurídico, 28 de nov 2015. Disponível em: Conjur – Ana Frazão: https://www.sedep.com.br/artigos/implementacao-de-programa-de-compliance-deve-atenuar-penalidades-a-empresas/. Acesso em 13 out.2025.

SILVA, Edson Cordeiro da. Governança Corporativa nas Empresas, 4ª edição. Rio de Janeiro: Atlas, 2016. E-book

Article originating from the Final Course Work of the Specialization in Compliance and ESG of the MBA USP/Esalq

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