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Consultation Responses and Policy Briefings


Consultations are our opportunity to share with Parliament and Government our unparalleled experience of advising 3,000 whistleblowers a year and working with hundreds of employers to improve workplace whistleblowing cultures. We respond to consultations so that we can argue for better laws and public policy to protect whistleblowers and the public interest. You can read our 2021 consultation responses by clicking the links below.

Protect Letter to Health and Social Care Committee (19.03.21)

We responded to the Health and Social Care Committee’s inquiry into the Department of Health’s white paper “Integration and Innovation: working together to improve health and social care”.

The white paper proposed a new Health Service Safety Investigations Body to investigate serious incidents of patient safety. We argued that any such body needs to be a prescribed person and should follow the principles in our Better Regulators Guide.

Protect Letter to PACA Committee (07.05.21)

We responded to the Public Administration and Constitutional Affairs Committee’s inquiry on “Propriety of governance in light of Greensill”.

We argued that whistleblowing can help to identify conflicts of interest within the civil service and government, and argued for changes to be made to the Ministerial Code and Civil Service Commission to better protect whistleblowers.

Protect Letter to Public Accounts Committee (02.06.21)

We responded to the Public Accounts Committee’s inquiry on “Initial lessons from the government’s response to the COVID-19 pandemic”.

We informed the Committee about the experiences of our Advice Line callers raising concerns about furlough fraud and public health risks. We made the case for legal standards on employers so that concerns are investigated and whistleblowers are not ignored, as well as explaining how regulators could better respond to whistleblowers during a public emergency.

Protect Letter to The Office for Product Safety & Standards (17.06.21)

We responded to the UK Product Safety Review.

We argued that mandatory standards on employers and regulators would better protect the public interest by ensuring that concerns about product safety are properly handled. We also recommended ways in which the Office for Product Safety & Standards could change its regulatory activities to improve transparency and confidence.

Protect Letter to BEIS (12.07.21)

We responded to the BEIS Department’s consultation on “Restoring trust in audit and corporate governance”.

We argued that a new regulator – The Audit, Reporting and Governance Authority (ARGA) – should be a prescribed person under whistleblowing law. We also argued that ARGA should have powers to set and enforce whistleblowing standards amongst employers.

Protect Letter to The Law Commission (21.07.21)

We responded to The Law Commission’s consultation for its 14th Programme of Law Reform.

We argued that The Law Commission should consider whistleblowing law as one of its next projects for review because UK whistleblowing law is nearly 25 years old and the UK is falling behind internationally. There are many groups of people unprotected by the current law and changes need to be made to improve access to justice.

Protect and WIN Letter to The Home Office (22.07.21)

Protect and the Whistleblowing International Network (WIN) responded to The Home Office’s consultation on “Legislation to counter state threats”.

We argued that the Official Secrets Act 1989 needs to be reformed to include a public interest defence for whistleblowers. We also argued in favour of a Statutory Commissioner to receive whistleblowing concerns, and highlighted the importance of keeping pace with international developments.

Protect submission to The Law Commission consultation on corporate criminal liability (26.08.21)

We argued that if corporate bodies were to have a defence to criminal liability then evidence of strong whistleblowing arrangements should form a part of that defence. We also argued that regulators should have more powers to impose civil penalties on employers who maltreat whistleblowers rather than pursuing criminal prosecutions.

Protect’s Public Interest Defence Briefing in the Official Secrets Act 1989

We produced a briefing laying out the arguments for why there needs to be a public interest defence added to the Official Secrets Act 1989, and the dangers of the proposed reforms from the Home Office that is danger of making whistleblowing seen legally as an act of espionage.

Protect’s Response to the Inquiry: Mobilising Action on Climate Change and Environment: Behaviour Change

Protect responded to this call for evidence, highlighting the importance of whistleblowing in the environmental sector, the lack of awareness and reporting, and suggesting that whistleblowing should form part of any consideration as to how culture and behaviour can be changed in the sector.

Protect’s Economic Crime (Transparency and Enforcement) Bill 2022 Briefing

We have written a briefing outlining key whistleblowing issues connected to the new Economic Crime (Transparency and Enforcement) Bill, including standards on regulators and standards on employers when dealing with concerns raised by whistleblowers.

Protect’s proposed amendments to the Economic Crime (Transparency and Enforcement) Bill 2022  

We have also proposed amendments to the Bill following the suggestions in our briefing around regulators, a Commissioner to Protect Whistleblowers, and an anti-SLAPP provision.

Protect’s Briefing on the amendments of the Economic Crime (Transparency and Enforcement) Bill

On March 3, amendments were put down for the Secretary of State to establish a Commission for the Protection of Whistleblowers. Please see the above for our briefing on the amendment which was sent to Members of Parliament ahead of the debate on Monday.

UPDATED Protect’s Briefing on the amendments of the Economic Crime (Transparency and Enforcement) Bill

On 7 March, we sent this briefing to some members of the House of Lords with an additional explanation on the SLAPP amendments.

Response to the consultation, Human Rights Act Reform: A Modern Bill of Rights 

Protect has responded to the Ministry of Justice’s consultation with focus on questions relating to Article 10, Freedom of Expression. Protect wants to ensure that the government considers the rights of whistleblowers and those who speak out in the public interest when considering reform and strengthening of this fundamental right. Protect also contributed to the Employment Lawyers Association’s working party response.

Protect has responded to the Ministry of Justice’s emergency call for evidence on Strategic Lawsuits Against Public Participation (SLAPPs). In our own response, we have focused on the experience and risk of whistleblowers facing SLAPPs. We are also a join signatory to the Anti-SLAPP Coalition’s response.


You can find our response here.

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