On October 6, 2015, the PRA and FCA published Policy Statements and final rules on whistleblowing. The rules require firms to implement internal whistleblowing procedures, to inform employees of the internal procedures and the whistleblowing services provided by the PRA and FCA and to ensure that employment contracts and settlement agreements do not deter employees from whistleblowing. The rules will apply to UK banks, building societies and credit unions with assets of £250 million or greater, PRA-designated investment firms, insurance and reinsurance firms within the scope of Solvency II and the Society of Lloyd’s and managing agents. UK branches of overseas firms are not in scope but the regulators will consider this further once the effectiveness of these new rules can be properly assessed. The scope of the new rules therefore captures those UK firms that fall within the Senior Manager and Certification Regimes which come into effect on March 7, 2016. Firms will have until September 7, 2016 to implement the new whistleblowing rules. However, firms will have to assign a senior manager who is a non-executive director as the whistleblowers’ champion by March 7, 2016 and that individual will be responsible for overseeing the firm’s implementation of the new whistleblowing rules.

The PRA Policy Statement is available at: http://www.bankofengland.co.uk/pra/Documents/publications/ps/2015/ps2415.pdf and the FCA Policy Statement is available at: http://www.fca.org.uk/static/fca/article-type/policy%20statement/ps-15-24.pdf.