Research
Student research project - CEMS students
To what extend do companies comply with Belgian whistleblowing legislation: an exploratory study (February - May 2026).
Once again this year, Transparency International Belgium worked alongside the students of the CEMS1 Master in International Management (MIM) from the Louvain School of Business at UCLouvain.
Transparency International Belgium sends a big thank you to Cedrid de Maere, Leonor Correia, Olivia De Munter and Oskar Mawdsley for their work as well as to the professors Loïc Decaux and Corentin Hericher for the follow-up and supervison.
Objectives of the report
This report examines how Belgian private companies have implemented the obligation stemming from the law of 28 November 2022 on the protection of whistleblowers. The European directive 2019/1937, adopted in October 2019, requires private-sector legal entities with at least 50 employees to establish internal channels for receiving and tracking reports (article 8) and defines the procedural requirements (Article 9). The Belgian transposition law goes beyond the minimum standards and broadens its scope to social and fiscal fraud.
The objective of this report was therefore to verify how the directive is implemented in 56 listed companies with more than 250 employees or staff in Belgium.
In terms of methodology,: students mixed desk top research and interviews. For the desktop research 4 indicators were established: 1. physical or digital presence of a reporting channel, 2. a publicly documented code of conduct, 3. a formal explicit non-retaliation policy and 4. tangible evidence of employee training and awareness initiatives. Open sources of 56 companies were explored to gather the information. Recognizing that technical compliance does not always equate to “a functional ethical culture”, the second phase focused on the maturity of systems. Therefor 9 semi-structured interviews were conducted.
Key findings:
Among the findings, this report suggests that formal compliance is largely established among the companies involved. 96.4% of companies have an identifiable reporting channel for whistleblowers. Students also note that most of the selected companies offer training on this topic and more than 57% of the companies provide an alert channel accessible to external stakeholders. They also tried to explore the corporate culture and thus understand how “speak up culture” has developed much more than the use of the term whistleblowing, which can be perceived as having a negative connotation.
However, other points still need to be improved, particularly in terms of communication. Communication on the channel and the existence of training on the subject of whistleblowers in the company can be difficult because it is sometimes scattered in several documents. The students also showed that there is a differentiation in access to information on whistleblowing within a company. Indeed, the people who actually access training are more often white-collar workers than blue-collar workers. An equally important point noted in this study is anonymity. If it is essential to any system of whistleblowers, the latter can complicate the real investigation (lack of information and difficulty in contacting people to obtain it).
Finally, many reports do not fall within the scope of the law but often focus more on the working environment, which shows that education and awareness still need to be strengthened around whistleblowers.
The Federal Ombudsman, coordinator for external reporting in the private sector, highlighted the same problem in his annual report for 2025. It states that only 16.5% of the complaints submitted to the Federal Ombudsman were declared admissible, compared with 11.5% in the federal public sector.
Check the report of the Federal Ombudsman here.
Conclusion
Transparency International Belgium encourages companies to publish and make accessible their compliance policies. Transparency is a key element of good practice.(or good corporate governance). Transparency International Belgium reaffirms the need to inform all workers about whistleblowing practices.
Transparency International Belgium recalls that this is a report made by students in a limited time with the aim of being a starting point for reflection on corporate compliance to the whistleblowing legislation Belgium. This work may contain errors due to the limited time and resources available for this research project.
Students are the future professionals who will invest in Integrity. Therefor Transparency International Belgium supports and encourages students and supervisors to work on corruption and integrity related projects. We are always open to discuss your proposal for collaboration.
Browse the report here: WHISTLEBLOWING COMPLIANCE REPORT 2026.