Since September 2016, the FCA has imposed additional requirements on financial services firms. These are listed in the FCA Handbook in the High Level Standards for Senior Arrangements, Systems and Controls, Chapter 18 (SYSC 18) and include requirements that firms must: 

• establish, implement and maintain appropriate and effective arrangements for the disclosure of reportable concerns by whistleblowers (SYSC 18.3.1R(1));
• prepare and maintain written whistleblowing procedures that are readily available to the firm's UK-based employees outlining the firm's processes (SYSC 18.3.1R(2)(e)(ii));
• ensure that the whistleblowing arrangements must at least be able effectively to handle disclosures of reportable concerns, including where the whistleblower has requested confidentiality or has chosen not to reveal their identity (SYSC 18.3.1R(2)(a)(ii)). Therefore, financial services firms are required to establish whistleblower procedures that permit anonymous reporting;
• appoint a "Whistleblowers' Champion" with individual responsibility for ensuring and overseeing the integrity, independence and effectiveness of the firm's policies and procedures on whistleblowing (SYSC 18.4). The Whistleblowers' Champion will have individual responsibility for overseeing the whistleblowing policies and procedures, and can be held directly responsible for failures in this space;
• prepare and maintain appropriate records of reportable concerns made by whistleblowers and the firm's treatment of these reports, including the outcome (SYSC 18.3.1R(2)(e)(i));
• prepare a report at least annually to the firm's governing body on the operation and effectiveness of its systems and controls in relation to whistleblowing. This report must maintain the confidentiality of individual whistleblowers (SYSC 18.3.1R(2)(f)(i));
• provide feedback to a whistleblower about a reportable disclosure made to the firm by such whistleblower, where this is feasible and appropriate (SYSC 18.3.1R(2)(d));
• include appropriate training for UK-based employees, managers of UK-based employees regardless of where the manager is based, and employees responsible for operating the firm's internal arrangements (SYSC 18.3.1R(2)(g)); and
• ensure the effective assessment and escalation of reportable concerns by whistleblowers where appropriate, including to the FCA or PRA (SYSC 18.3.1R(2)(b)).

A failure to comply with the above obligations may be considered a breach of SYSC 18 and leaves the regulated firm vulnerable not only to reputational damage and individual claims of unfair treatment, but also to direct enforcement action from the Regulator, which could result in substantial fines both for the firm and the Whistleblowing Champion personally. 

In addition, the firm must prepare prompt reports to the FCA regarding each case the firm contested (but lost) before an employment tribunal where the claimant successfully based all or part of their claim on either detriment suffered as a result of making a protected disclosure in breach of section 47B of the Employment Rights Act 1996, or being unfairly dismissed under section 103A of the Employment Rights Act 1996 (SYSC 18.3.1R(2)(f)(ii)).