In-house and operations · Irish HR lead, in-house counsel, compliance manager
Refresh a whistleblowing policy for an Irish employer
An Irish employer has a whistleblowing policy written before the current statutory framework and a reporting channel that routes to a shared HR mailbox. The review checks the policy, the channel and the acknowledgement timetable against what is required.
- First draft
- A gap analysis against the current policy comes back from one run, ahead of the policy committee.
The problem
Step 01 of 05
Open the matter in Ireland
Jurisdiction is set to Ireland, with the current policy, the channel configuration note and the last two reporting logs uploaded.
Project Halcyon: SPA warranties and disclosure
Buy-side warranty review, disclosure analysis and cited due-diligence grid.
- Client
- Halcyon Bidco Ltd
- Reference
- WC-2026-0412
- Practice area
- Corporate / M&A
- Jurisdiction
- England and Wales
- Responsible partner
- E. Vance
No conflict check on file.Chat, on this matter
Compare warranties with the disclosure letter.
Three high-priority exceptions require action: the unregistered charge, the change-of-control right and the tribunal claim.
Send a message… (@ to mention tools)BalancedPrepare for- 25 Aug
Disclosure exceptions matrix
Chat
- 21 Aug
Disclosure exceptions matrix
Run · completed · 560 credits
- 18 Aug
Project Halcyon: Disclosure Letter
Document · indexed
- 16 Aug
Project Halcyon: Share Purchase Agreement
Document · indexed
- 4 Aug
Matter opened
Opened
Step 02 of 05
Run the gap analysis
Prepare for: Work-Stream Memo. Each requirement is stated, matched to the current policy wording or process and marked as met, partial or absent.
Agent
Jurisdiction
Prepare for
Deliver as
Instruction
What should the agent look for?Documents
Drop a contract, or pick one from the matter
Also on the matter
- Offer_letter_v3.pdf2 pages
- Staff_handbook_2025.docx61 pages
- Board_minute_14_Aug.pdf3 pages
Platform model · zero data retention · audit register onStep 03 of 05
Read the channel finding
The shared mailbox is the central problem: it does not restrict access to authorised persons and the logs show reports being forwarded to line managers.
6 items need your confirmation14 authorities · Where we lookedSenior Associate Employment Contract: English Law Review
Summary
- 1.
Clause 9(c), non-competeHigh
The 12-month prohibition on working for any law firm anywhere in the UK, Ireland or EU, in any capacity, is almost certainly wider than reasonably necessary and therefore unlikely to be enforceable.
Tillman v Egon Zehnder Ltd [2019] UKSC 32 - 2.
Clause 11, data and monitoringHigh
Blanket contractual consent is not an adequate basis for general employment processing, special-category data or unrestricted monitoring.
UK GDPR, Arts 6 and 9 - 3.
Clause 4, holiday carry-overHigh
The unconditional five-day cap conflicts with mandatory carry-over rights where sickness, statutory leave or employer failure prevents leave being taken.
Working Time Regulations 1998, regs 13 to 13A
- 1.
Step 04 of 05
Check the timetable
Acknowledgement and feedback periods are set out as dates from receipt, and the logs show two reports where neither was met.
6 items need your confirmation14 authorities · Where we lookedSenior Associate Employment Contract: English Law Review
Summary
- 1.
Clause 9(c), non-competeHigh
The 12-month prohibition on working for any law firm anywhere in the UK, Ireland or EU, in any capacity, is almost certainly wider than reasonably necessary and therefore unlikely to be enforceable.
Tillman v Egon Zehnder Ltd [2019] UKSC 32 - 2.
Clause 11, data and monitoringHigh
Blanket contractual consent is not an adequate basis for general employment processing, special-category data or unrestricted monitoring.
UK GDPR, Arts 6 and 9 - 3.
Clause 4, holiday carry-overHigh
The unconditional five-day cap conflicts with mandatory carry-over rights where sickness, statutory leave or employer failure prevents leave being taken.
Working Time Regulations 1998, regs 13 to 13A
- 1.
Step 05 of 05
Take the rewrite and the process change
Action items separate the policy rewrite from the channel change, because the second is the one that takes budget and time.
Replace the UK/Ireland/EU non-compete with a 3 to 6 month restriction tied to competing corporate-law work.
Replace blanket data consent with a lawful-basis clause and a separate monitoring notice.
Remove the five-day carry-over cap and reference the statutory carry-over rules.
Narrow the client non-solicit to clients dealt with in the final 12 months.
Add an explicit working-time opt-out withdrawal mechanism.
Confirm the bonus clause states the discretion is exercised in good faith.
What comes back
A document, not a transcript.
- Every statutory requirement matched to the current policy or process and marked met, partial or absent.
- The reporting channel finding, evidenced from the logs rather than asserted from the configuration note.
- An acknowledgement and feedback timetable expressed as days from receipt, with the two missed reports identified.
- A split action list separating the document rewrite from the process and system change.
Authorities it checks
- Protected Disclosures Act 2014 (Ireland)
- Directive (EU) 2019/1937
What it does not do
- It does not configure or procure a reporting channel.
- It does not investigate any of the reports in the logs; it reads them for process evidence only.
- It does not approve the policy, which remains a decision for the employer's own committee.