Key Considerations

The Disclosure Procedure will need to be clear on:

  • Eligible recipients of a disclosure
    • Internal 
    • Internal, where there is a conflict if interest
    • External
  • Emergency disclosure
  • Immunities and protections for people connected with the investigation:
    • Discloser
    • Person being investigated
    • Investigator
    • Professional advisors (forensic, HR, Financial)
  • Penalties
    • Discloser
    • Retaliation against the Discloser
  • Compensation and reinstatement