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Silence isn’t evidence: what a healthy speak-up culture looks like in the data.

A board is told there were no whistleblowing reports this year and two grievances, both resolved. It sounds reassuring. It is also exactly what a culture where people have stopped speaking up looks like.

By Ron EldridgeOctober 2026 · 6 min read · Source: great{with}talent speak-up and exit practice; FCA SYSC 18; NHS England Freedom to Speak Up policy · Fact-checked October 2026

On this page
  1. Two organisations with the same log
  2. Six signs of a healthy speak-up culture in the data
  3. Concerns arrive, and from everywhere
  4. Concerns arrive early
  5. People are willing to put their name to it
  6. People hear back
  7. Nobody pays for it
  8. The survey agrees with the log
  9. Read it alongside what leavers say
  10. What regulators are looking for
  11. Where to start
In short

Six signs that tell a safe, quiet culture from a silent one, four survey questions to ask, and the exit-data cross-check.

Speak-up arrangements are usually judged by what comes through them. That is the wrong way round. A channel that receives nothing could be a channel nobody needs, or one nobody trusts, and the reports themselves cannot tell you which. To know, you need data from the people who did not use it.

Two organisations with the same log

SignalQuiet because it is healthyQuiet because people have stopped speaking
Concerns raisedSome, from across the organisation, many of them early and minorFew, and the ones that arrive are serious, late or anonymous
Know how to raise a concernMost peopleMost people: they know the route, they just do not use it
Would feel safe raising oneHigh, including about their own managerLow, especially about a manager
Believe it would be acted onHighLow: “nothing would happen”
Saw something and did not report itRareCommon
What leavers sayConduct rarely featuresLeavers describe behaviour that never reached a formal route

Six signs of a healthy speak-up culture in the data

  1. Concerns arrive, and from everywhere

    Some volume is a good sign. In our experience the more useful question is not how many concerns an organisation receives but where they come from. A large team with nothing in a year deserves a question, not a gold star. Look at the spread by site, function and level, not only the total.

  2. Concerns arrive early

    A mix of minor and serious concerns suggests people raise things while they can still be fixed. If almost everything that arrives is serious, people may be waiting until it is bad, or until they are leaving.

  3. People are willing to put their name to it

    An anonymous route is essential. But if nearly every concern is anonymous, people are telling you they do not expect to be safe if they are known. A healthy direction of travel is a rising share of named concerns, with the anonymous route still open.

  4. People hear back

    Track whether the person who raised a concern was told what happened, and how long it took. Feedback is the part of speaking up that persuades the next person, and it is the easiest part to measure.

  5. Nobody pays for it

    Ask people who raised a concern, some months later, whether they were treated differently as a result. Detriment, or the belief that it follows, empties a channel faster than anything else.

  6. The survey agrees with the log

    Four questions, asked anonymously and reported by team above a minimum group size:

    • I know how to raise a concern about behaviour at work.
    • I would feel safe raising a concern about my own manager.
    • If I raised a concern, I believe it would be acted on.
    • In the last twelve months I have seen behaviour at work that I thought was wrong and did not report.

    Where knowing is high but safety and belief are low, the channel exists but is not trusted.

Detriment, or the belief that it follows, empties a channel faster than anything else.

Read it alongside what leavers say

Exit data is a cross-check many organisations already hold. People who are leaving have less to lose. If leavers from one area describe conduct that never appeared in the speak-up log, that tells you something about trust in that area. We suggest one exit question asking whether the leaver experienced or witnessed bullying, harassment or other misconduct, followed by a second asking whether they reported it.

What regulators are looking for

  • Financial services. For the firms its whistleblowing rules apply to (broadly, UK banks and building societies other than small deposit-takers, PRA-designated investment firms and Solvency II insurers), the FCA requires arrangements that can handle concerns from people who want confidentiality or will not give their name, and a report to the firm’s governing body at least annually on how those arrangements are working. Other firms may adopt the rules as good practice.
  • The NHS. NHS England’s national Freedom to Speak Up policy sets out how speaking-up arrangements should work, with a reflection and planning tool to help organisations improve them.
  • Sexual harassment. Since 6 April 2026, disclosures about sexual harassment can qualify for whistleblowing protection in their own right.

The question underneath is the same each time: not whether a policy exists, but whether people use it, and are safe when they do.

Where to start

Ask the four survey questions. Break the answers down by team, with a minimum group size. Put them next to the speak-up log and the last year of exit data. Where the three agree, you have evidence. Where they disagree, you know where to look. For the legal duty that makes this evidence matter from 30 October 2026, see The duty to prevent sexual harassment; for regulated financial firms, Culture evidence for FCA-regulated firms.

Drawn from great{with}talent’s speak-up and exit practice. Sources: FCA Handbook SYSC 18.1 and 18.3.1R (whistleblowing arrangements; report to the governing body at least annually), checked 16 October 2026; NHS England, national Freedom to Speak Up policy and reflection and planning tool; Employment Rights Act 2025 (sexual harassment disclosures, from 6 April 2026). No statistics are used. SafeSpace gives staff an independent route to raise concerns, named or anonymously, and audits whether they would.

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