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Spotlight on Critical U.S. Benchmarking Metrics

United States Whistleblowing Statistics
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Summary

The landmark 2002 Sarbanes-Oxley Act (SOX) in the United States reinforced the self-evident best practice of an effective internal reporting program and set the tone for a cascade of similar regulation around the globe. More than 20 years later, data regularly shows the U.S. as having some of highest rates of internal reporting globally. 

The ability for individuals to raise a concern of misconduct through an internal reporting mechanism without fear of retaliation provides critical signals for an organization’s risk profile and cultural health. While there are no “right” numbers in benchmarking data, we encourage readers of this white paper to consider how these metrics compare in context to their own organization’s operations.

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Methodology

Following careful consideration, we are releasing specific key benchmarking metrics at the U.S. level for the first time. Each metric reflects 2024 data from organizations headquartered in the United States, meaning some reporting may have occurred outside of the U.S. 

For statistical accuracy, our analysis includes only organizations that received 10 or more reports in 2024. To remove the impact of outliers that might skew the overall reporting data, we calculate each benchmarking metric by organization and then identify the median (midpoint) across the total population.  

The full NAVEX 2025 Regional Whistleblowing & Incident Management Benchmark Report exhaustively analyzes 10 different benchmarking metrics across four global regions. Most metrics are depicted by the headquarters region and the region of report origination.

Reports per 100 Employees

Median reporting value

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The Reports per 100 Employees benchmarking metric allows organizations of all sizes to compare total unique contacts across all reporting channels which include web, hotline, open-door and any other form of report intake.  

Organizations based in the U.S. had a median 1.78 Reports per 100 Employees in 2024. That compares to a median 0.67 Reports per 100 Employees for Europe-based organizations. Globally, the median Reports per 100 Employees was 1.57. 

How to calculate: Find the number that reflects all the reports gathered by all reporting channels, divide that number by the number of employees in the organization and then multiply it by 100. For this metric to accurately compare to the calculation we’ve provided, organizations should not exclude any reports.

Anonymous Reporting Rate

Median reporting value

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The Anonymous Reporting Rate benchmarking metric shows the percentage of all reports submitted by reporters who chose not to disclose their identity.  

Organizations based in the U.S. had a median 51% Anonymous Reporting Rate in 2024. In Europe, organizations had a median 65% Anonymous Reporting Rate. The global median was 54%. 

How to calculate: To calculate the percentage of anonymous reports, divide the number of reports submitted by an anonymous reporter by the total number of anonymous and named reports received.

Substantiation Rate

Median reporting value, closed cases

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The overall Substantiation Rate reflects the median rate of allegations from both named and anonymous reporters that were closed as substantiated or partially substantiated. A high Substantiation Rate reflects a well-informed employee base making high-quality reports, coupled with effective investigative processes.  

U.S.-based organizations recorded a median 45% of closed cases as substantiated. In Europe, organizations recorded a median 47%. Globally, the substantiation rate was 46%. 

How to calculate: Divide the number of allegation reports that were closed as substantiated or partially substantiated by the total number of reports that were closed as substantiated/partially substantiated or unsubstantiated as defined. We also note that there is a category described as “insufficient information” which is excluded from these calculations.

Top Report Risk Categories

Three colored circular progress charts show percentages: 54.5% in orange, 50.8% in blue, and 53.8% in green. Each circle is mostly filled, with a small empty segment at the top. Three circular progress charts showing percentages: the first displays 20.0% in red, the second displays 21.4% in blue, and the third displays 20.0% in green. Three circular progress charts showing percentages: 3.8% in orange (left), 6.2% in blue (center), and 4.3% in green (right), each with a colored segment indicating their value.
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Report Risk Category describes a total of six distinct categories of misconduct – Accounting, Auditing and Financial Reporting, Business Integrity, Workplace Conduct, Environment, Health and Safety, Misuse or Misappropriation of Assets and “Other.” Below the six Risk Categories are a total of 24 Risk Types. We encourage readers to download our full Regional Whistleblowing and Incident Management Benchmark Report for additional guidance. 

Risk Category invites ample opportunity for interpretation. We invite readers to consider how these metrics compare to their own organization’s operations and programs. 

How to calculate: First ensure each report is sorted into one of the six Risk Categories or the 24 Risk Types as defined in the appendix of our major reports. Then, divide the number of reports in each of the six categories by the total number of reports. Please note, when we are using the median for each category, the totals won’t necessarily add up to 100%.

Definitions of Report Risk Categories

Workplace Conduct (formerly named HR, Diversity and Workplace Respect) are reports that often relate to employee relations or misconduct. Risk Types include Discrimination, Harassment, Workplace Civility, Retaliation, Compensation and Benefits, Substance Abuse, and general or Other HR.

Business Integrity are reports that address how an organization interacts with third parties, data, legislation, regulations, patients or customers.

Accounting, Auditing and Financial Reporting are reports that pertain to these functions in an organization (e.g., financial misconduct, internal controls, audit).

Conclusion

It is always important to acknowledge there are no “right” outcomes in benchmarking data. Each organization faces a unique operating environment and culture. Yet our enduring hope is that these metrics provide context for organizations seeking to improve – to provide reporters a means to raise concerns of misconduct without fear of retaliation, and to form the basis of a culture of ethics and compliance. Organizations can use this information to better assess where they stand amid their local, regional and global peers, and use those comparisons to consider ways to advance their programs.

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