---
title: "Building a speak-up culture: a checklist | Speak Out Safe"
description: A practical checklist for boards and trustees on leadership, policy, reporting routes, case handling, records and learning, based on UK guidance.
image: https://speakoutsafe.uk/hubfs/website-2026/sos-safeguarding-lead.webp
---

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Safe reporting culture

# How to build a speak-up culture: a practical checklist for boards and leaders

A practical checklist for boards and trustees on leadership, policy, reporting routes, case handling, records and learning, based on UK guidance.

[Speak Out Safe](https://speakoutsafe.uk/blog/author/speak-out-safe)

 Oct 14, 2026

---

Every organisation says it wants people to speak up. Far fewer can show that people actually do, that concerns are handled well, and that those who raise them are treated fairly afterwards. A speak-up culture is not created by a policy document. It is built through leadership, clear routes, consistent handling and visible follow-through.

This checklist is written for boards, trustees and senior leaders. It draws on official guidance and on the standards football and charity regulators now apply, and it is designed to be worked through at a single board or committee meeting.

## Why it matters now

Expectations have risen. Since 6 April 2026, [sexual harassment has been expressly listed](https://www.legislation.gov.uk/ukpga/1996/18/section/43B) as a matter that can form the basis of a protected disclosure, and from 30 October 2026 employers must take "all reasonable steps" to prevent sexual harassment of their employees, according to the [Government's implementation timeline](https://www.gov.uk/government/publications/implementing-the-plan-to-make-work-pay-and-employment-rights-act/plan-to-make-work-pay-and-employment-rights-act-timeline-update). In the charity sector, the Charity Commission received [594 whistleblowing disclosures in 2025 to 2026](https://www.gov.uk/government/publications/whistleblowing-disclosures-made-to-the-charity-commission-for-england-and-wales-2025-to-2026/whistleblowing-disclosures-made-to-the-charity-commission-for-england-and-wales-2025-to-2026), the highest number in the last ten years. In football, the [Premier League's safeguarding standards](https://resources.premierleague.pulselive.com/premierleague/document/2025/07/18/333f5bdc-2070-4ad5-9733-a42d833766d5/2025-26-Safeguarding-Standards.pdf) expect safeguarding to be a standing or regular Board agenda item.

Boards that can evidence a working speak-up system are in a far stronger position than those that rely on a policy and hope.

## 1. Leadership and accountability

- A named board member holds responsibility for whistleblowing and safeguarding reporting. The [EFL Safeguarding Standards](https://cdn.port-vale.co.uk/sites/default/files/2024-08/EFL%20Safeguarding%20Standards%2024-25.pdf) expect a Board-level representative with leadership responsibility for safeguarding.
- The board receives regular reports on concerns raised, themes, response times and outcomes, without individual names.
- Senior leaders talk openly about why speaking up matters, and thank people who do.
- Leaders understand that retaliation, including by colleagues, is unlawful. The law protects workers from detriment for making a protected disclosure, and [employers can be liable for detriment caused by co-workers](https://www.legislation.gov.uk/ukpga/1996/18/section/47B).

## 2. A clear and current policy

- There is a written whistleblowing policy, even though there is no legal requirement for one. [GOV.UK guidance](https://www.gov.uk/guidance/whistleblowing-guidance-for-employers) sets out the risks of going without, and [Acas advises](https://www.acas.org.uk/whistleblowing-at-work/responding-to-a-whistleblowing-disclosure) employers without one to put one in place as soon as possible.
- The policy explains what whistleblowing is, names sexual harassment and safeguarding concerns explicitly, and makes clear that victimisation is unacceptable.
- It sets out timeframes for handling concerns and the kind of feedback a reporter can expect.
- It confirms that reporters do not need evidence before raising a concern.
- It covers volunteers, contractors and others who are not employees, as well as staff.
- It is reviewed at least annually and after any serious incident, in line with the [Charity Commission's expectations for policies](https://www.gov.uk/guidance/safeguarding-and-protecting-people-for-charities-and-trustees).

## 3. Routes people trust and can use

- There is more than one route: line managers, a designated lead, and a channel that does not depend on approaching someone face to face.
- Reporters can choose to be named, confidential or anonymous.
- Anonymous reporters can still receive questions and feedback. The [EHRC's technical guidance](https://www.equalityhumanrights.com/guidance/sexual-harassment-and-harassment-work-technical-guidance) suggests employers consider an online or externally run system that allows anonymous reports.
- Routes are accessible to people with different first languages, literacy levels and communication preferences.
- Different groups, such as staff, volunteers, young people and visitors, can reach the right people quickly.
- Routes are widely promoted, not buried in a handbook. Football's standards expect whistleblowing procedures to be "easily understood and widely promoted".

## 4. Consistent, fair handling

- Named, trained people receive and handle concerns, with clear roles and restricted access.
- The reporter's identity is kept confidential and shared only with those who need to know.
- Reporters are kept informed of progress and told the outcome where appropriate, as [Acas recommends](https://www.acas.org.uk/whistleblowing-at-work/responding-to-a-whistleblowing-disclosure).
- There are agreed timeframes. Where EU rules apply, [Directive (EU) 2019/1937](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L1937) requires acknowledgement within seven days and feedback within three months.
- Conflicts of interest are managed, so no one investigates a concern about themselves or their line manager.
- Escalation routes to regulators, the police or safeguarding authorities are understood and used when required.

## 5. Records and evidence

- Every concern is logged, including informal ones. The EHRC recommends centralised records detailed enough to analyse trends.
- Each case shows who handled it, what was done, and why it was closed.
- Records are held securely, with access controlled and an audit trail.
- Data protection obligations are met, with appropriate agreements in place with any third-party provider.

## 6. Learning and improvement

- The board reviews themes, not just numbers, and asks what they say about culture and risk.
- Low reporting is treated as a question, not as reassurance.
- The organisation asks whether people feel safe to speak up, and what stops them. The EFL standards expect clubs to identify barriers that stop children and adults at risk from speaking out.
- Lessons from cases lead to changes in policy, training or practice, and those changes are communicated.
- Training on how to raise and receive concerns is given at induction and refreshed regularly.

Boards wanting a structured framework can look to [ISO 37002:2021](https://www.iso.org/standard/65035.html), which provides international guidelines for whistleblowing management systems, built on the principles of trust, impartiality and protection.

## Where Speak Out Safe fits

Speak Out Safe supports several items on this list directly: a dedicated portal and QR code for each organisation or part of it, tick-box and voice note reporting in 29 languages, anonymous two-way messaging, role-based access for case handlers, administrators and read-only users, and case management with notes, closure codes, statistics and an audit trail. The platform runs under an ISO/IEC 27001:2022 information security management system, holds Cyber Essentials and is offered with a data processing agreement covering UK and EU GDPR. It supports a speak-up culture, but it does not replace leadership, and no system can.

This article is general information, not legal advice.

To work through these points in more detail with your board, [download our free Whistleblowing Readiness Checklist](https://speakoutsafe.uk/whistleblowing-readiness-checklist).

[Safe reporting culture](https://speakoutsafe.uk/blog/tag/safe-reporting-culture)

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