2023 Asia Pacific Conduct Watch Survey Report

Published date: 25 June, 2023

On June 23, 2023, Deloitte officially released the 2023 Asia Pacific Conduct Watch Survey Report. If you would like to access the full report, please click the link on thr right. Moreover, we will also organize offline seminars in the near future, which you are welcome to attend.

Background of the Report

From March 31 to May 1, 2023, Deloitte launched the 2023 Asia Pacific Conduct Watch Online Survey and invited board and senior management with responsibility or oversight related to whistleblowing to participate in the survey. After analysing more than 500 questionnaire responses across Asia Pacific, Deloitte observed the prevailing organisational awareness, attitudes, set-up and capabilities in the region and understood the main concerns and challenges faced by entities and their employees regarding whistleblowing. In the report, Deloitte provided insights about how to make whistleblowing more effective.

Features of this Survey

The organizations participating in the Survey covered more than 10 industries, including both public and private companies from industrial manufacturing, financial services, and consumer business. 67% of the respondents are operating in multiple countries/regions, and 74% were key decision-makers for whistleblowing within their organizations.

The Survey addressed the following areas:

  • Strategy and culture
  • Policies and procedures
  • Implementation and execution
  • Reporting and monitoring

The Importance of Whistleblowing Programs

In current policy of non-prosecution of criminal compliance which are launched as a pilot by the procuratorial authority, whether an enterprise has established an effective compliance system is one of the important factors that prosecutors consider when deciding whether to prosecute. An internal whistleblowing programs is an indispensable part of an effective compliance plan, and it is also a significant way for enterprises to effectively detect and prevent misconduct.

The advantages of setting up a whistleblowing program include:

  • Generally, it is easier to detect illegal and irregular behaviours within the enterprise. Employees in production, sales, finance, legal and other departments have the best understanding of the misconduct within their own business line and industry. The earlier the misconduct is revealed, the less likely the company's legal risks and economic losses will occur.
  • Internal whistleblowing is one of the important standards to measure the integrity and effectiveness of a company's compliance system. The effective establishment of an internal whistleblowing programs can enable the company to have knowledge of compliance issues existing in business development, thereby the company could respond quickly and then carry out investigations, which can also enable the company to avoid facing the "out of control" situation in the future.

Key takeaways from the Report

Point 1: Purpose of whistleblowing and types of disclosures

As shown in the Survey, the main purposes of the current whistleblowing programs within organizations include:

  • Improve culture of ethics and integrity—— 71%
  • Detect fraud and other misconduct——66%
  • Encourage positive and transparent working environment——59%

We also concluded from the Survey that the types of internal disclosures of within organizations mainly include three types:

Currently, whistleblowing channels are increasingly used to report concerns relating to people matters. It is evident that Changing work practices and
cultural norms have impacted the purpose and use of whistleblowing.

Deloitte perspective

With the gradual diversification of the types of internal reporting issues, organizations should make good use of the whistleblowing program to gain a multi-dimensional understanding of its operations, to be provided with more useful information for operational decision making, and continuously improve the corporate governance environment.

Point 2: Accountability

As shown in the Survey, less than half of the respondents indicated that overall responsibility for whistleblowing rested at the board level. So, it is clear that a significant number of decision-makers have not yet recognized that an effective whistleblowing program plays an important role within the organizations.

Deloitte perspective

Overall responsibility for whistleblowing should reside at the board level, so that whistleblowers feel their concerns are taken seriously and acted upon with confidentiality.

Deloitte perspective

Point 3: Key challenges on whistleblowing

The survey results showed that the main challenges for organizations on whistleblowing programs came from the mindset and awareness of employees, mainly including concerns by employees over independence of reporting process, lack of employee awareness of the whistleblowing program and fear of retaliation against employees.

Deloitte perspective

Establishing an independent process, with well-communicated policies and procedures builds trust which is critical to an effective whistleblowing program.

Point 4: Measuring the effectiveness of the whistleblowing programs

The survey results showed that 70% of respondents measured the effectiveness of their whistleblowing program, but only 30% of them relied solely on the number of reports received to measure effectiveness. Thus, a significant number of organizations have not yet succeeded in selecting the right indicators to evaluate the effectiveness of their whistleblowing programs.

Deloitte perspective

Selecting the right metrics is key to measuring the effectiveness of your whistleblowing program. Relying solely on report volume as a measure of effectiveness may be misleading as it does not take into account the reasons for the high or low volumes observed.


The internal whistleblowing program is an indispensable part of the compliance program and one of the important factors for evaluating the effectiveness of the criminal compliance program. Therefore, in the process of establishing an effective compliance program, an enterprise should establish a complete compliance reporting system, so as to minimize the compliance risk of enterprises through mutual supervision among members and between internal and external partners. In that way, internal whistleblowing system can truly play a role and promote the effective implementation of the compliance plan.

If you want to know more about the report, please click the link on the right and leave your contact information, we will then send the report to your email. Meanwhile, we will host offline seminars in Beijing, Shanghai, Shenzhen and Hong Kong in the near future, you are welcome to register for it.

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