Dealing with a whistleblower in internal criminal investigations

Produced in partnership with Ben Cooper of TLT , Chantal Peters of TLT and James Chadwick of TLT
Practice notes

Dealing with a whistleblower in internal criminal investigations

Produced in partnership with Ben Cooper of TLT , Chantal Peters of TLT and James Chadwick of TLT

Practice notes
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This Practice Note provides guidance on the practical issues that may arise following receipt of a whistleblower report from the perspective of the corporate entity (including limited companies, partnerships and LLPs) receiving the report. For guidance from the perspective of those representing whistleblowers, see Practice Note: Representing whistleblowers in internal criminal investigations.

A corporate entity may receive reports on a broad spectrum of suspected wrongdoing, from breaches of internal company policy, to employment issues such as allegations of discrimination, to allegations of serious criminality. The latter is the focus of this note, although some principles will apply universally.

Whistleblowing policy

Benefits of implementing a whistleblowing policy

While whistleblowing legislation does not impose a requirement on companies to have a whistleblowing policy (although note there are specific rules in this respect for listed companies and those in the financial services sector), the development and implementation of robust and well-publicised policies and procedures for dealing with whistleblowing is best practice and has a number of benefits:

Ben Cooper
Ben Cooper

Solicitor/Partner, TLT


Ben leads TLT's economic crime team and has over 20 years' experience advising governments, financial institutions, corporates and individuals on all aspects of economic crime. This includes advice on money laundering, sanctions, tax evasion, bribery and corruption, terrorist proliferation financing, corporate ethics, asset tracing, fraud, complex investigations and criminal proceedings. 

Ben also has extensive experience assisting clients to develop, implement and operate global economic crime compliance programmes utilising his experience in senior compliance roles for HSBC, Global Head of Financial Crime Functions and Global Head of AB&C.

Ben also worked for the Asset Recovery Agency and Serious Organised Crime Agency (now the National Crime Agency) and so is uniquely placed to advise clients on handling enquiries and investigations from law enforcement agencies.

Chantal Peters
Chantal Peters

Partner, TLT


Chantal specialises in contentious financial regulatory work, litigation and legal project management. She is a Leading Partner in The Legal 500, recognised for ‘her expertise in contentious financial regulatory work, litigation and legal project management”, and is also co-chair of Women in Banking and Finance in Manchester. 
 
She has extensive experience advising financial institutions on FCA enforcement investigations, internal and whistleblowing investigations. She routinely advises on the SMCR, the FCA and PRA Code of Conduct and fitness and propriety issues.  
 
Chantal has advised financial institutions in connection with a range of issues including conduct and culture, systems and controls, cyber security, AML and anti-bribery, regulatory reporting, operational resilience and the treatment of customers. 
 
Her experience includes advisory and risk management work, supporting clients on numerous Skilled Person’s reviews, past business reviews, remediation and change programmes.  

Recent experience includes:

• crisis response to large scale data breaches (including engagement with three regulators);
• conduct and operational risk investigations; and  
• multiple Section 166 reviews. 
 
Chantal’s industry knowledge is supplemented by an understanding of the inner workings of firms, gained through secondments at multiple major banks.

James Chadwick
James Chadwick

Partner, TLT


James specialises in financial services litigation and contentious financial regulation. He is recognised as a leader in the field in The Legal 500 and widely regarded by his clients as the premier financial services litigation, contentious regulatory and investigations lawyer in the northwest.  
 
Described as “fast becoming the go-to banking litigation partner in the UK, not just the North”, James specialises in financial services litigation and contentious financial regulation. This year, he has been shortlisted as Dispute Resolution Lawyer of the Year at The Legal 500 Northern Powerhouse Awards 2025. 
 
He has extensive retail banking experience and has advised some of the most high-profile UK regulated firms on key issues affecting their portfolios including the implementation of the Consumer Duty (for which James is TLT’s Consumer Duty Champion), crisis response to widely publicised data breaches (including engagement with the FCA, ICO and tPR), PPI strategy, the regulatory intervention in to the motor market, conduct and operational risk investigations. James advises on litigation and rectification strategy, risk management and issues flowing from loan portfolio acquisitions.  
 
James routinely advises market-leading financial institutions and their senior managers on a range of regulatory investigations, including internal and whistleblowing investigations. His experience spans all aspects of the Senior Managers and Certification Regime, the FCA and PRA Code of Conduct and associated fitness and propriety issues. 
 
His contentious regulatory practice includes complex advisory, strategic and risk management work. James has extensive experience advising across a broad range of regulatory issues including redress and remediation, systems and controls, regulatory reporting, operational resilience, fraud, mis-selling and the treatment of customers.  
 
James manages key relationships with financial institutions. His client base includes high-street banks and other financial services providers across the sector. By combining legal insight and commercial acumen, James is considered by many clients as their trusted advisor. 

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United Kingdom

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