Time to Retire the Whistle? Rethinking the Language of Ethical Reporting

The financial services industry has long relied on employees to act as a final line of defence against misconduct. From exposing sanctions breaches and insider trading to highlighting fraudulent transactions and compliance failings, internal reporting has played a crucial role in uncovering wrongdoing. Yet the word used to describe those who take such action - whistleblower - has become a barrier in itself. It is a term burdened with stigma and, in many institutions, evokes fear, betrayal, and reputational risk rather than integrity and courage.

If we are serious about building a culture of transparency, compliance, and trust, then it may be time to reassess our language. More than semantics, this shift could reshape how we perceive ethical reporting, how people feel about coming forward, and ultimately, how resilient our institutions are in the face of misconduct.

The Problem with Whistleblower: A Word Out of Step with Modern Ethics

The term whistleblower originated from the world of sports, likening the act of calling out wrongdoing to a referee blowing the whistle to stop play. It once implied vigilance, fairness, and rule enforcement. However, the connotation has darkened considerably over time.

In today's discourse, a whistleblower is often framed as a disloyal employee or internal saboteur. High-profile cases, from Edward Snowden’s NSA disclosures to the Panama and Pandora Papers, have reinforced associations with controversy, media storms, and institutional retaliation. While these individuals were often vindicated in the long term, the short-term consequences they endured such as job loss, legal threats, or exile, are seared into the public imagination.

In financial services, a sector known for hierarchical culture and discretion, such associations are even more dangerous. The idea of “going outside the system” is viewed as radical, disruptive, and potentially career-ending. The result is silence. In Protect’s 2020 report, The Best Warning System: Whistleblowing During Covid-19, 41 percent of individuals who raised COVID-19-related concerns reported that their employers ignored them. This reflects a lack of confidence not only in reporting mechanisms but in employers’ willingness to act.

The Language of Ethical Reporting Matters

Language is a powerful determinant of organisational culture. It shapes perceptions, influences behaviour, and establishes the moral lens through which actions are judged. By labelling an employee a whistleblower, we imply that they are stepping outside the norm, disrupting order, and acting against the organisation. This discourages others from speaking up.

In the UK, firms are increasingly shifting away from this language, promoting what regulators and professional bodies refer to as a speak-up culture. Encouraging staff to raise a concern rather than blow the whistle helps embed ethical reporting into day-to-day operations without triggering defensiveness or suspicion. The terminology is plain, culturally resonant, and aligned with the UK’s evolving regulatory tone.

The Financial Conduct Authority (FCA) has long emphasised the importance of "speak-up, listen-up" cultures within regulated firms. Their public messaging underscores the need for trusted, independent mechanisms for internal disclosures, backed by leadership commitment and active follow-through.

Rebranding Whistleblowing: A Precedent for Change

The idea of rebranding whistleblowing is not without precedent. The tech industry and parts of the ESG space now talk about raising ethical concerns, risk transparency, or internal accountability pathways to create less confrontational environments for speaking up. In the UK financial sector, similar shifts are occurring.

TSB Bank, for example, refers to its internal policy as Speak Up and Be Heard, aiming to create a culture where employees feel supported in raising concerns. While specific data on the programme's impact has not been published, its tone reflects a growing desire to shift the perception of internal disclosures from disruptive to constructive.

Such reframing is not a superficial exercise. It reflects a deeper understanding of psychological safety and behavioural risk. Employees are more likely to raise concerns when reporting is seen as a normal part of safeguarding the organisation, not a dramatic act of last resort.

The Regulatory Balance: Evolving Language Without Losing Legal Protection

While there is a strong case for cultural and linguistic reframing, organisations must proceed with care. The term whistleblower remains central to legal frameworks such as the UK’s Public Interest Disclosure Act (PIDA) and the US Securities and Exchange Commission’s Whistleblower Programme. These laws confer important protections and in the case of the SEC, financial rewards to those who disclose wrongdoing.

Replacing the term entirely in formal documentation could weaken legal clarity or cause confusion. A better approach is dual-track: retain whistleblower where necessary for statutory alignment, but adopt terms such as speak-up channels or internal concerns reporting in internal culture-building communications. This enables organisations to meet their legal obligations while reducing the stigma associated with raising concerns.

A Call for Ethical Branding in Financial Crime Compliance

As financial crime risks become more sophisticated, spanning sanctions evasion, greenwashing, cyber-enabled fraud, and cross-border corruption, organisations must be able to detect and respond swiftly. This relies not only on technical controls but on a workforce willing and empowered to speak up when something appears wrong.

In areas such as anti-bribery and corruption (ABC), fraud prevention, and sanctions compliance, frontline staff are often the first to spot misconduct. If these individuals fear that reporting concerns will damage their careers, they may stay silent leaving firms exposed to regulatory, reputational, and criminal liability.

By reframing how we speak about internal reporting (moving from whistleblowing to a normalised, supported act of raising a concern) we send a clear message that compliance is everyone’s responsibility. And that those who act in the organisation’s best interests will be heard, protected, and respected.

Conclusion: Retire the Whistle, Not the Watchfulness

In a sector where trust underpins every transaction, the ability to detect and address misconduct before it metastasises is not just a regulatory necessity, it is a strategic imperative. The whistleblower, as a concept, has served financial services well in highlighting the need for robust internal reporting and protections. But the term itself has become encumbered by baggage: a word that, for many, evokes fear, stigma, and retaliation rather than respect, courage, and civic duty.

If we want to embed a culture of integrity, we must begin by examining how our language shapes perceptions. Words are not passive; they either invite people into the compliance ecosystem or alienate them from it. Encouraging employees to raise concerns through trusted speak-up channels signals that speaking up is not an act of betrayal, but one of stewardship.

This linguistic shift must be accompanied by systemic reform: clear reporting pathways, visible executive support, independent oversight, and credible follow-up. But the cultural transformation begins with how we talk about those who hold the line. By reframing internal reporting as a normal, respected part of organisational life, we lay the groundwork for a more resilient and transparent financial system.

It is time to retire the whistle. Not the watchfulness. Not the vigilance. Not the integrity that drives it. Let us empower those who raise concerns with the clarity, confidence, and dignity they deserve.

What Does Your Speak-Up Culture Say About Your ABC Controls?

A strong anti-bribery and corruption framework is not just about controls and policies, it is about culture. If your employees do not feel safe to raise concerns, your defences are already compromised.

At OpusDatum, we help financial institutions design and enhance ABC programmes that enable ethical behaviour, detect red flags, and foster true speak-up environments. From risk assessments to forensic investigations, policy design to training, we build frameworks that go beyond compliance.

Read our ABC case study to see how we helped one institution rebuild trust and strengthen controls from the inside out. Contact us to learn how we can help you do the same.