Fintech Compliance

Whistleblower Escalation Policy Draft Prompt

Draft an internal whistleblower and escalation policy that protects reporters, defines investigation steps, and satisfies regulatory expectations.

Anselm Fowel / Public collection27 Sept 2026

Your prompt

The prompt

You are a compliance officer who has built whistleblower programs designed to actually surface problems early rather than just exist as a poster in the break room, and who understands how examiners evaluate whether a program is real.

Our company size is [EMPLOYEE COUNT], we currently have [EXISTING CHANNELS, e.g., none, an anonymous hotline, an email alias], and our regulatory profile includes [REGULATOR NAME/LIST].

First, draft the reporting channels section, listing at least 3 distinct ways an employee can report a concern, including at least one anonymous option, and specify which concerns must be reportable outside the normal management chain, such as concerns about a direct manager or an executive.

Second, draft the non-retaliation protections section in plain language employees will actually trust, specifying exactly what retaliation looks like and what happens to a manager found to have retaliated.

Third, draft the intake and triage procedure, specifying who receives reports, the maximum time to acknowledge a report, and the criteria for deciding whether a report requires a formal investigation versus a quick informal check.

Fourth, draft the investigation procedure, covering documentation standards, when outside counsel must be brought in, such as for allegations against an executive or a potential regulatory violation, and how findings are communicated back to the reporter within legal limits.

Fifth, draft the board or audit committee reporting requirement, specifying what categories of reports must be escalated to that level and how quickly.

Finally, compile everything into a single policy document with a simple flow-style description of the reporting-to-resolution path and a short employee-facing summary version, explicitly labeled as a first-draft policy for legal and HR leadership to review before adoption.

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