NAVEX Report Reveals Stark Differences in Corporate Whistleblowing Practices Between Private and Public Companies

A groundbreaking analysis of corporate whistleblowing practices has uncovered substantial differences in internal reporting between private and public organizations, according to the NAVEX 2025 Whistleblowing & Incident Management Benchmark Report.

The study, which examined reports from over 4,000 organizations representing nearly 69 million employees, revealed that private companies received significantly more internal reports per 100 employees compared to public companies. Specifically, private organizations reported 1.80 reports per 100 employees, while public companies averaged 1.10 reports per 100 employees.

Notably, private companies demonstrated a higher tendency to substantiate reported matters, with a 50% substantiation rate compared to 43% for public companies. The research also highlighted differences in response strategies, with private companies more likely to separate employment upon substantiating a case, while public companies typically opted for disciplinary actions.

Workplace civility emerged as the most reported concern, representing nearly 18% of all reports and substantiated at a 46% frequency. Carrie Penman, Chief Risk and Compliance Officer at NAVEX, emphasized the critical nature of addressing workplace behavior, noting that tolerating poor treatment can potentially lead to broader compliance failures.

The report identified several significant trends, including a record-high overall substantiation rate of 46% and a notable shift in reporting channels. For the first time, web and digital form reports surpassed traditional hotline reporting, with alternative reporting channels showing the highest substantiation rate at 61%.

An emerging concern highlighted in the study was the relatively low substantiation rate for retaliation incidents, which remained at just 18% despite a slight increase in reporting. Jane Norberg, a partner at Arnold & Porter and former SEC Office of the Whistleblower Chief, suggested this could indicate less sophisticated investigation practices that might increase litigation and external reporting risks.

The comprehensive analysis also tracked interesting shifts in other reporting categories, with insider trading and political activity reports increasing by 67% and 32% respectively, while product quality and safety reports declined from 1.93% to 1.75%.

These findings underscore the evolving landscape of corporate compliance and the critical role of robust, responsive internal reporting mechanisms in maintaining organizational integrity and culture.