Does the undertaking have an internal reporting channel for whistleblowers?

Whistleblowing channel is a separate question from integrity policy

This question specifically concerns the existence of an internal whistleblowing channel: a channel where employees can report wrongdoing, with safeguards for confidentiality and against retaliation. This is different from the question of whether there is an anti-bribery policy — a company can have is a policy against bribery and corruption one without a separate whistleblowing channel, and vice versa. In many questionnaires both items are listed separately, so check whether your client sees them as two separate lines or as one combined question.

As evidence, a whistleblowing procedure or regulation is usually requested, possibly with a reference to the tool or external office that receives the report (think of a whistleblowing office at a law firm). If this document is missing, then "no" is the factually correct answer — even if informally something can occasionally be reported to a manager. An informal line does not count as a channel in the sense this question is usually intended. If there is a regulation but it has never been communicated to staff, mention that in the explanation to your answer; some clients ask about that separately, others do not. This topic often touches the same section as the question about a procedure for reporting conflicts of interest, because respondents often cluster integrity questions — so check whether your answer file does not accidentally merge those two.

Basis in the VSME governance module

The VSME standard of EFRAG mentions the existence of a whistleblowing channel as part of the base module on governance and conduct. The standard does not ask about the content of reports or about numbers, only about whether the channel exists. For the exact wording and the accompanying explanation, the EFRAG text is the designated source.