As of 6 April 2026, sexual harassment is directly recognized as protected whistleblowing under UK law. This change simplifies categorizing harassment disclosures. However, it raises the question of whether to integrate these reports into your existing speak-up channel or manage them separately.
Many compliance teams are grappling with this decision. Your HR team might handle harassment investigations through one system, while your ethics hotline manages other disclosures through another. The new law doesn't dictate a specific approach, but it requires that your chosen method is effective.
Here's how to decide.
The Decision You Are Facing
Should sexual harassment reports be integrated into your centralized speak-up channel, or should they remain within a separate HR-managed process?
This decision involves more than just software. It's about who sees the report first, how quickly you can respond, whether you can track patterns across business units, and whether employees trust the channel enough to use it.
Choosing the wrong path can create gaps. Reports might fall through the cracks, investigators may miss related complaints, and you could struggle to demonstrate consistent handling when questioned by regulators.
Key Factors Affecting Your Choice
Your Current Reporting Volume and Complexity
If you operate across multiple UK sites or countries, fragmented systems make spotting patterns difficult. A harassment issue in Manchester and another in Edinburgh might be connected, but you'll miss it if they're logged separately.
Employee Trust in Your Existing Hotline
If your speak-up channel is trusted and used regularly, adding harassment reports makes sense. If employees view the hotline as a dead end, routing sensitive harassment disclosures there will backfire.
Regulatory and Legal Exposure
Under the Employment Rights Act 2025, mishandling a harassment disclosure can trigger both harassment and whistleblowing claims. This dual exposure necessitates audit trails, consistent documentation, and proof that you protected the reporter from retaliation.
Your Investigation Team's Capacity and Expertise
Harassment investigations require specific skills. If your compliance team lacks this expertise, centralizing everything won't help. You need the right people handling the right cases, regardless of where the report lands.
Path A: Centralize Through Your Speak-Up Channel
Choose this path when:
- You operate in multiple locations and need organization-wide visibility.
- Your hotline effectively handles confidential or anonymous reports.
- You want to track harassment alongside other misconduct.
- You need consistent case management, documentation, and audit trails.
- Your compliance team can route cases to HR investigators while maintaining oversight.
What This Looks Like in Practice:
All reports come into one platform. Employees can report anonymously or confidentially, 24/7, in multiple languages. The system automatically routes harassment cases to trained HR investigators while keeping compliance informed. You maintain one source of truth for all disclosures, enabling analytics, trend spotting, and demonstrating consistent handling to regulators.
The Advantage:
You can prove your speak-up culture works. When asked how you handled harassment disclosures, you have centralized records, timestamps, investigation notes, and outcome tracking. You can show patterns, response times, and substantiation rates.
The Risk:
If employees don't trust your hotline, they won't use it. Centralizing everything into a channel that feels bureaucratic or unresponsive will drive reporting underground. Ensure the channel is genuinely accessible and that employees believe action will be taken.
Path B: Keep Harassment in HR's System
Choose this path when:
- Your organization is small enough that HR sees everything anyway.
- You have a mature, trusted HR case management process in place.
- Your compliance hotline is primarily used for financial misconduct or regulatory violations.
- Your HR team has deep expertise in harassment investigations and wants full control.
- You're confident you can track anti-retaliation measures and demonstrate consistent handling.
What This Looks Like in Practice:
Employees report harassment directly to HR through an established channel (email, HR portal, in-person meeting). HR manages the investigation from intake to resolution. Compliance gets notified of outcomes but doesn't handle the case directly.
The Advantage:
Harassment investigations stay with the team that knows how to conduct them. You avoid the risk of compliance staff mishandling sensitive interpersonal dynamics. Employees who trust HR can go straight to the team they're comfortable with.
The Risk:
You lose visibility. If harassment reports live in HR's system and other disclosures live in compliance's system, you can't connect the dots. A pattern of misconduct by one manager might not surface until it's too late. You also can't easily demonstrate to regulators that you're handling all whistleblowing disclosures consistently.
Path C: Hybrid Model with Clear Routing Rules
Choose this path when:
- You need the visibility of centralization but want specialized handling for different issue types.
- Your organization is large enough to support multiple investigation teams.
- You can define clear routing rules and ensure nothing falls through the cracks.
- You have technology that can centralize intake while routing cases to the right team.
What This Looks Like in Practice:
All reports come into one intake system. The platform automatically routes harassment cases to HR investigators, fraud cases to internal audit, and safety issues to EHS. Compliance maintains oversight and can see all cases, but subject matter experts handle the investigations. You get centralized reporting, decentralized investigation, and consistent documentation.
The Advantage:
You get the best of both worlds: visibility across the organization and specialized expertise where it matters. Employees have one place to report, but their concern gets handled by the right team.
The Risk:
This only works if your routing rules are clear and your teams communicate. If HR and compliance don't talk to each other, you've just created a more sophisticated way to drop cases.
Summary Matrix
| Factor | Centralized Speak-Up Channel | HR-Managed System | Hybrid Model |
|---|---|---|---|
| Best for | Multi-site organizations needing visibility | Small orgs with strong HR teams | Large orgs with specialized investigation teams |
| Reporting Access | Anonymous, 24/7, multi-language | Direct to HR, often during business hours | Anonymous intake, specialized routing |
| Pattern Detection | Strong | Weak | Strong |
| Investigation Expertise | Requires training or routing | Built-in | Built-in |
| Regulatory Defense | Easiest to demonstrate consistency | Harder to prove centralized oversight | Strong if documentation is consistent |
| Employee Trust Requirement | High trust in hotline needed | High trust in HR needed | Moderate; employees just need to know where to start |
The new law doesn't tell you which path to choose. It tells you that whichever path you choose has to work. Employees need to know how to report. They need to feel safe doing it. And you need to be able to prove you handled their disclosure appropriately.
If you can't answer those three requirements clearly right now, you have until 6 April 2026 to fix it.
