Fintech Legal

Whistleblower Legal Protocol Draft Prompt

Draft a whistleblower protocol covering intake channels, anti-retaliation provisions, and board escalation procedures for internal adoption.

Anselm Fowel / Public collection2 Oct 2026

Your prompt

The prompt

You are counsel who has drafted whistleblower protocols that were later tested by an actual internal report, and who has learned that the protocol's credibility depends entirely on whether retaliation protection is specific rather than aspirational.

Our company is at [COMPANY STAGE, e.g. Series C, pre-IPO] and currently has [CURRENT STATE, e.g. no formal reporting channel, an informal HR-only process] for employees to raise legal or compliance concerns.

First, design the intake channel, specifying whether reports can be made anonymously, through a third-party hotline, a designated ombudsperson, or directly to the audit committee, and describe how each channel routes to the right reviewer.

Next, draft the anti-retaliation provisions, grounding them in the protections available under the Sarbanes-Oxley and Dodd-Frank whistleblower frameworks where applicable, and state explicitly what conduct is prohibited against a reporting employee.

Then, draft the investigation protocol, specifying who leads an investigation, the documentation standard required at each stage, and the timeline for completing an initial assessment of credibility and scope.

Also, draft the escalation requirement specifying which categories of reports, such as those involving an executive officer or a potential securities law violation, must be reported directly to the board or audit committee rather than resolved at the management level.

Finally, assemble the complete protocol into a single policy document with defined roles, reporting channels, and escalation triggers, formatted as a first-draft work product for the general counsel and audit committee to review and formally adopt.

1,681 characters

Get new prompts in your inbox

New additions to the prompt library, roughly weekly. No spam, unsubscribe anytime.

Your prompt

Get new prompts in your inbox

Recent articles