Skill

legalcode-uk-whistleblower-program-builder

Build, audit, and design UK whistleblowing frameworks under the Public Interest Disclosure Act 1998 (PIDA) and Employment Rights Act 1996 Part IVA (ss.43A-43L, s.47B, s.103A) for England and Wales. Covers worker status (extended s.43K definition), all six categories of qualifying disclosure (s.43B), public interest requirement (post-ERRA 2013), protected disclosure routes (ss.43C-43H), detriment and automatic unfair dismissal risk, unlimited compensation exposure (s.123A), interim relief (s.128), vicarious liability (s.47B(1A)), the Jhuti tainted-decision doctrine, Kong separability principle, settlement agreement restrictions, FCA/PRA SYSC 18 sector-specific requirements (whistleblowers' champion, annual board report, SYSC 18.3 settlement agreement term), SM&CR interaction, prescribed persons reporting (ERA s.43F; Prescribed Persons Order 2014 as amended to SI 2025/604), internal and external reporting channel architecture, investigation sequencing and independence, board and audit committee escalation, employer-facing policy design, UK GDPR / DPA 2018 data-handling obligations, and NHS Freedom to Speak Up framework. Produces COMPLIANT / PARTIAL / NON-COMPLIANT / CRITICAL DEFICIENCY gap analysis with remediation roadmap and Glass Box audit trail. Use when building a whistleblowing programme from scratch, auditing an existing programme for PIDA/FCA compliance gaps, reviewing employment agreements for void confidentiality language, assessing detriment or dismissal risk in a specific case, designing investigation procedures, responding to an FCA SYSC 18 supervisory review, or advising a board on governance obligations. Jurisdiction: England and Wales (primary); Scotland and Northern Ireland share PIDA but have different prosecution authorities and some distinct overlay provisions — note where relevant.