NAVEX, the global leader in integrated risk and compliance management software, has released its 2025 Whistleblowing & Incident Management Benchmark Report. It features an in-depth analysis of the industry’s largest dataset of reported incidents derived from NAVEX customers that received 10 or more internal reports in 2024. This group of over 4,000 organizations, representing nearly 69-million employees covered by their programs, led to 2.15 million reports available for analysis, the highest level ever. These reports represent a treasure trove of data points to inform the insights compliance officers, executives, and boards of directors use to understand the successes, opportunities, cultural health, and operational risks within their organizations.

In response to company requests and new this year, NAVEX analyzed internal reporting data for different structures of company ownership – publicly traded companies, private organizations, government entities and education organizations – to show how reporting metrics differ within these groups with notable findings.

Overall, Reports per 100 Employees showed ongoing record levels of activity for internal reporting systems. For a median organization, reporters are continuing to utilize internal reporting at the record level of 1.57 Reports per 100 Employees found in 2023. Further, reported incidents were substantiated at the highest levels ever seen in NAVEX’s reporting.

Workplace Civility concerns again represented the greatest share of 24 Risk Types for reports in 2024 at a median of nearly 18% of reports and were substantiated with a frequency of 46%. “High levels of incivility and inappropriate behavior in a workplace directly impact organizational culture, productivity, employee retention and willingness to speak up,” said Carrie Penman, Chief Risk and Compliance Officer at NAVEX. “We know that many organizations consider these types of reports to be ‘not a compliance issue,’ but tolerating poor treatment of colleagues can lead to compliance failures.”

In addition, for the first time, this year’s report analyzed nearly 144,000 conflict-of-interest (COI) disclosures made through NAVEX One Disclosure Manager. This provides a deeper understanding of the dynamics within the realm of COIs and other disclosures. Overall, the highest percentage of disclosures were submitted by individual contributors who were most likely to disclose personal relationships in the workplace. Executives were most likely to disclose board positions and financial holdings.

The 2025 benchmark report reveals several key themes and notable findings, including:

• Private companies received a significantly higher level of Reports per 100 Employees than public companies (1.80 vs. 1.10 Reports per 100 Employees) and are more likely to substantiate these matters (50% vs. 43%). In addition, private companies demonstrated a higher tendency to separate employment when a case is substantiated compared to their public counterparts, who are more inclined to impose disciplinary actions.
• On the flip side, private companies most often take no action on a substantiated matter, so it appears they are more likely to be operating on the extremes of the potential outcomes. Interestingly, a greater median share of reports received by private companies are related to Business Integrity, which include a variety of legal violations, (21% vs. 18%), while public companies lead in Workplace Conduct reports (58% vs. 53%).
• Other noteworthy changes among the 24 Risk Types are Insider Trading and Political Activity, which increased by 67% and 32%, respectively. Product Quality and Safety dropped from a four-year high median of 1.93% in 2023 to 1.75% in 2024, a notable decline considering the quality challenges experienced in the aviation, food safety, and other industries in 2024.
• As noted above, the overall median Substantiation Rate reached a record high of 46%. This upward trend suggests that organizations may soon achieve a 50% substantiation rate for reports. Such a milestone would highlight the effectiveness of compliance programs in investigative practices, reporter education, and the ability to attract high-quality reports. This significant progress underscores the growing maturity and impact of these programs.
• For the first time, the frequency of reports made via a Web or digital form overtook those made via Hotline (phone) while reports made in person, via mail or other channels outside of Web and Hotline, grew from 34% in 2023 to 37% in 2024. Of the reporting channels, the median Substantiation Rate for other channels was greatest (61%) followed by Web (40%) and Hotline (33%). Regardless of the originating factors, it is clear that the way reporters are speaking out about misconduct is shifting and programs should be empowered to effectively track all intake channels.
• In 2024, the median reporting rate for retaliation incidents rose from 2.84% to 3.08%, yet overall reporting of these matters remains low with substantiation rates at a mere 18% when compared to the overall substantiation rate of 46%. This data highlights a critical issue: companies must remain vigilant, fostering safer and more transparent work environments.

"The most effective compliance programs have strong anti-retaliation components. The NAVEX findings related to the low substantiation rate (18%) on retaliation complaints may indicate less sophisticated and thorough investigation of these types of complaints, which can lead to more litigation and external reporting risk,” said Jane Norberg, Arnold & Porter Partner, and former Chief of the SEC Office of the Whistleblower. “The data we will discuss in the webinar and the NAVEX report are crucial measures for understanding and implementing key risk and compliance strategies this year and beyond.”

For more insights, including findings not in the written 2025 Whistleblowing & Incident Management Benchmark Report, join the webinar at 9am PT / 12pm ET on March 20. Jane Norberg, Arnold & Porter Partner and former Chief of the SEC Office of the Whistleblower, Carrie Penman, NAVEX Chief Risk and Compliance Officer, and Anders Olson, NAVEX Senior Manager of Data Science, will host an informative discussion on the results of this year’s analysis.

NAVEX is trusted by thousands of customers worldwide to help them achieve the business outcomes that matter most. As the global leader in integrated risk and compliance management software and services, we deliver solutions through the NAVEX One platform, the industry’s most comprehensive governance, risk and compliance (GRC) information system. For more information, visit NAVEX.com and our blog. Follow us on Twitter and LinkedIn.

NAVEX

+1 617-388-5773

anita.lo@navex.com

https://navex.com

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