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When Should You Blow the Whistle?

A Cautionary Tale

I’ve always been intrigued by the philosophy of whistleblowing. It is an act of conscience and not motivated by self-interest.

A broad view of whistleblowing is the disclosure by organization members (former or current) of illegal, immoral, or illegitimate practices under the control of their employers, to persons or organizations that may be able to effect action. This definition includes whistle-blowers who use internal channels (e.g., a hot line or ombudsperson) or external channels (e.g., the external auditors or the SEC) to blow the whistle.

There are four elements of the whistleblowing process: the whistleblower, the whistleblowing act or complaint, the party to whom the complaint is made, and the organization against which the complaint is lodged. The act might be labeled as one of “dissidence,” somewhat analogous to civil disobedience. It may be seen as disloyal by some but in the public interest by others.

Given that the act of whistleblowing is a personal choice, the key to whether an individual will blow the whistle on wrongdoing is whether the whistle-blower perceives organizational policies are designed to encourage whistleblowing.

Research has shown that what whistleblowers hope and believe their speaking out will achieve, is the correction of what they perceive as an organizational wrongdoing (e.g., fraudulent financial statements). This research also found that not everyone who perceives a wrongdoing, acts upon that perception. In fact, only 42 percent said they were ready to blow the whistle.

The Association of Certified Fraud Examiner report data on organizational culture that includes whistleblowing. The results for 2022 are as follows.

Initial Detection of Occupational Frauds from the ACFE 2022 Global Study on Occupational Fraud and Abuse

Detection Method

Percentage Reported

Median Loss




Internal Audit



Management Review



Documentation Examination



By Accident 



Account Reconciliation



External Audit 



Automated Transaction/Data Monitoring 






Notified by Law Enforcement






As you can see, most of the whistleblowers come from within the organization. In fact, only 4% of whistleblowing is done by external auditors, which raises the question: What is the purpose of an audit? This is a complex issue and the subject of future blogs. Whislte

Whistleblowing regulations attempt to protect individuals when they behave responsibly towards society in light of irresponsible behavior by their organizations. This certainly is the motivation for the anti-retaliation provisions of both the Sarbanes-Oxley Act and the Dodd-Frank Financial Reform Act. The acknowledgement of the need for such protection, however, implies that moral agency, autonomy and responsibility are problematic in organizations, or at the very least, that they do not come naturally and are not welcomed when they arrive. When organizations establish an ethical culture and anonymous channels to report wrongdoing, they create an environment that supports whistleblowing and whistle-blowers while controlling possible retaliation.

Whistleblowing always involves an actual or at least declared intention to prevent something bad that would otherwise occur. It always involves information that would not ordinarily be revealed. Most ethicists agree whistleblowing is an ethical action. According to the “standard theory” on whistleblowing, whistleblowing is morally required when it is required at all; people have a moral obligation to prevent serious harm to others if they can do so with little costs to themselves.

The morality of whistleblowing might be viewed from the perspective that corporations have a moral obligation not to harm. De George identifies five criteria when whistleblowing is morally permitted. Briefly, (1) the firm's actions will do serious and considerable harm to others; (2) the whistleblowing act is justifiable once the employee reports it to her immediate supervisor and makes her moral concerns known; (3) absent any action by the supervisor, the employee should take the matter all the way up to the board, if necessary; (4) documented evidence must exist that would convince a reasonable and impartial observer that one's views of the situation is correct and that serious harm may occur; and (5) the employee must reasonably believe that going public will create the necessary change to protect the public and is worth the risk to oneself.

De George’s criteria establish the foundation for moral behavior to occur when contemplating whistleblowing. He rejects the position that external whistleblowing is always morally justifiable, and also rejects the position that external whistleblowing is never morally justifiable. Basically, his position is that the whistleblower should have a moral motivation to engage in the act (i.e., to expose unnecessary harm, and illegal or immoral actions).

One question that has always interested me is how a whistleblower can bounce back after blowing the whistle, which is a painstaking process. It requires resilience. In other words:

Commitment: The desire to do the right thing regardless of the consequences.                                                                                   Consciousness: Awareness: Act consistently and apply moral convictions to your daily behavior.                                                Competence: The ability to collect and evaluate information, and to foresee the potential consequences of actions on others.

Would-be whistleblowers should ask: How they could take an action that family and loved ones would be proud of and how they would want to be remembered.

Ethics and morality go hand in hand. If you face an ethical crisis in the workplace, consider first whether real harm may be done to others if you don’t do everything in your power to correct the situation. Then, commit to acting ethically; first considering the consequences of your actions on others including yourself. No one is obligated to take actions that might harm one’s own interests. However, our moral obligation to society does obligate us to right a wrong when we see one that has occurred.

Posted by Steven Mintz, Ph.D., aka Ethics Sage, on February 29, 2024. You can sign up for his newsletter and learn more about his activities at: