Whistleblowing Hotline

A whistleblowing hotline is a channel through which employees, business partners and others can report situations such as corruption, bribery, fraud, mobbing, discrimination, data breaches or regulatory breaches within the company securely. A well-designed hotline allows problems to be identified before they escalate or become public.

Legal Framework

There is no general law in Turkey requiring all companies to set up a whistleblowing hotline. However:

• Some sector rules and corporate governance principles provide for internal control and reporting mechanisms.
• Groups operating in the EU or with EU subsidiaries may be subject to EU Whistleblowing Directive 2019/1937, which requires businesses with fifty or more employees to establish internal reporting channels.
• In competition and anti-bribery compliance programmes, an ethics hotline is seen as a key indicator of the programme’s effectiveness; see Competition Compliance Programme.

Protection of Reporters

Under the Labour Law, an employee applying to administrative or judicial authorities to fulfil obligations to the employer or to pursue their rights is not a valid reason for termination. Retaliation against an employee who reports in good faith may lead to bad faith compensation or discrimination compensation. Company policy should expressly prohibit and sanction retaliation.

KVKK and Confidentiality

Reports to the hotline contain the personal data of both the reporter and the person reported. Setting up the hotline therefore requires planning notice, restricted access rights, retention periods and, if the hotline is operated by a third-party provider, a data processing agreement.

After a Report

Reports should be assessed by an impartial team and, where needed, an internal investigation opened. If action is to be taken against an employee as a result, termination procedure, including obtaining the employee’s defence, must be followed.