Association of Corporate Investigators

Reflections from the ACi Whistleblowing Investigations Forum

On World Mental Health Day, it feels particularly poignant to reflect on the insights shared at our recent Whistleblowing Investigations Forum. As we heard from our exceptional speakers and engaged delegates, the conversations about corporate accountability, regulatory compliance, and investigative best practices were invaluable. But beneath every case study and procedural discussion lay a profound human cost that we cannot afford to overlook.

The Whistleblower’s Journey: A Personal Toll

Yasmine Motarjemi’s harrowing testimony set the tone for understanding what whistleblowers truly endure. Her story wasn’t just about food safety failures or corporate misconduct- it was about the systematic dismantling of a professional life. When Yasmine discovered that babies were choking on biscuits, that baby formula contained ink, and that a culture of fear actively discouraged reporting, she faced an impossible choice that no professional should ever have to make.

The personal consequences she experienced—harassment, victimisation, lawsuits, blacklisting, and professional isolation – illustrate why her advice to “think twice before you report” resonates so powerfully. She asked a question that cuts to the heart of the matter: “Is the issue really worth it?” Not because the issues aren’t serious, but because the financial, professional, and social consequences for whistleblowers can be devastating.

What was particularly striking was her observation that colleagues stayed silent, authorities turned away, and industry peers abandoned her. This isolation compounded the psychological burden exponentially. Even after winning her case following a long legal battle, the damage to her wellbeing and career had already been done.

Yasmine’s passion is food safety, yet she was dismissed due to her “opinions.” She found that senior executives had no ethics or scruples. Products were not being tested robustly. But recalled products meant employees didn’t get bonuses, so lack of reporting was encouraged and reporting was actively discouraged. The company prioritised metrics over safety, targets over truth.

When Yasmine went higher up the company to report her concerns, the company didn’t even interview her. An external investigation was presented in court, and four people signed a report saying there had been no harassment—despite the reality she had lived. This institutional gaslighting adds another layer of psychological trauma to an already devastating experience.

A Pattern of Silence: The Broader Context

Edward Henry KC’s keynote on the Post Office Horizon scandal provided sobering context that Yasmine’s experience is not isolated. Over fifteen years, 700-900 subpostmasters were wrongfully prosecuted based on faulty IT data, yet no credible whistleblower emerged from within the Post Office itself to prevent this catastrophe. At least four people took their own lives. At least 60 died without seeing justice.

Why this silence? Edward’s analysis revealed a culture where the Horizon system was treated as a “false god”- infallible and beyond question. When subpostmasters reported problems, they were told “you are the only one experiencing issues.” Those who challenged the system were prosecuted. As Edward noted, employees who witnessed this drew the obvious inference: “raise your head, and it will be lopped off.”

The Post Office’s own General Counsel testified he could recall only one whistleblowing complaint during his entire tenure. As Edward concluded: “Silence was rational; speaking was not survivable.”

This echoes Yasmine’s experience precisely. In both cases, organisations measured success by outcomes that served the business rather than prevented harm. Edward observed how corporate cultures are “shaped by what they count”- when success is measured by closed cases or maintained production targets rather than safety and truth, whistleblowers become “saboteurs of targets” rather than guardians of integrity.

The psychological mechanism is identical: create an environment where speaking up threatens your livelihood, isolate those who dare to challenge the system, and ensure others witness the consequences. The mental health toll isn’t incidental – t’s instrumental to maintaining silence.

The Investigator’s Burden: Secondary Trauma and Ethical Complexity

The discussions with Eve Giles, Hayley Humphries, Ashu Sharma, and Thomas Twitchett highlighted another dimension we must address: the mental health impact on investigators themselves. When examining sexual harassment cases, investigators require trauma investigation training not just for the quality of their work, but for their own psychological protection.

The duty to investigate versus the duty of care to the subject creates an ethical tightrope that weighs heavily on investigators. They must approach cases from a fact-finding perspective without pre-judgement, all while managing anonymous reports, protecting witnesses, and navigating complex data protection requirements. The emotional labour of maintaining objectivity while hearing traumatic testimonies takes its toll.

Under the new Senior Managers Test introduced by ECCTA, the pressure on investigators has intensified further. Senior managers now face personal criminal liability if they don’t take reasonable steps to prevent fraud and economic crime. The stakes are higher than ever, creating additional stress for everyone involved in the investigative process.

There’s also the moral injury that can occur when investigators work within systems that have already decided the outcome. Maintaining integrity while facing institutional pressure to validate predetermined conclusions creates profound psychological stress for ethical investigators.

Cyber Whistleblowing: New Frontiers, New Pressures

Charlie Weston-Simons and Dr Ayala Maurer-Prager’s session on cyber whistleblowing investigations revealed yet another layer of complexity. The SolarWinds case demonstrated how technical complexity can create additional barriers for whistleblowers. When raising concerns requires explaining sophisticated cyber vulnerabilities to non-technical audiences, the psychological burden of “not being understood” or “not being taken seriously” intensifies.

The recommendation that CSOs should report directly to CEOs rather than falling under IT enablement speaks to the need for whistleblowers to have clear, protected channels that don’t require navigating multiple layers of hierarchy -each layer representing another potential point of discouragement or dismissal.

When organisations treat technology systems as infallible “black boxes” beyond questioning, they create similar dynamics to what Yasmine experienced in food safety and what occurred in the Horizon scandal – a culture where challenging accepted wisdom becomes framed as disloyalty rather than due diligence.

Creating Cultures of Psychological Safety

As Yasmine noted with frustration, despite the EU Directive on whistleblowing, there are no meaningful consequences for companies who fail to act on reports. In food safety, this can mean dire consequences. In mental health terms, this impunity creates a chilling effect that silences potential whistleblowers who correctly assess that speaking up offers risk without protection.

Protect, the whistleblower charity, reports that 40% of whistleblowers who seek help are simply ignored. Edward’s analysis of the Horizon case demonstrated how even Britain’s Public Interest Disclosure Act (PIDA) proves “insufficient when the culture is toxic.” In surveys, 70% of finance-sector whistleblowers reported being victimised or ignored after speaking up.

The question posed to our delegates about whether whistleblowers should be rewarded generated mixed responses. But perhaps we’re asking the wrong question. Before we debate rewards, shouldn’t we first ensure that whistleblowers aren’t punished? That they don’t face the isolation, harassment, and career destruction that Yasmine experienced?

As Edward powerfully stated: “When an institution demands absolute loyalty and punishes any whisper of doubt, no formal protection will produce whistleblowers.”

Practical Steps Forward

The forum provided concrete guidance that also serves mental health objectives:

For organisations:

• Implement robust whistleblowing policies that genuinely protect reporters – not just on paper, but in lived practice
• Provide trauma-informed training for investigators
• Ensure independence in investigations to prevent institutional pressure
• Create clear reporting lines that bypass potential conflicts of interest
• Measure success by harm prevention, not just case closure rates or production targets
• Recognise that people who identify risks represent opportunities to build resilience, not threats to be neutralised
• Never prioritise bonuses, metrics, or reputation over safety and truth

For whistleblowers:

• Keep a detailed journal documenting concerns and events (Yasmine’s key advice)
• Assess whether the issue genuinely warrants the personal cost -understanding the reality that serious issues can have significant financial, professional and social consequences
• Seek support networks before and during the process
• Understand that even “winning” may come at a significant personal price
• Consider external channels when internal cultures prove hostile

For investigators:

• Secure evidence early and protect witnesses throughout
• Plan interview sequencing carefully to minimise repeated trauma
• Partner with technical experts when needed to share the cognitive load
• Frame discussions around genuine fact-finding to reduce defensiveness
• Include lessons learned in reports to prevent future occurrences
• Maintain independence and resist pressure to validate predetermined conclusions
• Recognise and address your own secondary trauma and moral injury

A Call to Action

On World Mental Health Day, we must acknowledge that whistleblowing frameworks aren’t just about compliance and risk management – they’re about human dignity and psychological wellbeing. Every whistleblowing case involves real people making extraordinarily difficult choices, often at great personal cost.

Yasmine Motarjemi’s courage in sharing her story, despite everything she endured, challenges us to do better. Her experience – finding that senior executives had no ethics, that reporting was actively discouraged, that she was excluded from conferences where she should have been celebrated as an expert -reveals the human cost of our failures to protect those who speak truth to power.

The patterns Edward Henry KC identified in the Horizon scandal, where “silence was rational; speaking was not survivable,” echo through Yasmine’s experience and countless others. When colleagues stay silent, when authorities turn away, when industry peers abandon those who raise concerns, we create psychological environments where doing the right thing requires sacrificing everything.

This is the reality we must change.

We extend our deepest gratitude to Yasmine Motarjemi for her powerful testimony and her ongoing commitment to food safety despite everything she has endured. To Edward Henry KC for his insightful analysis of systemic failures in the Horizon scandal. To Eve Giles, Joyce Nkini-Iwisi, Cheryl O’Shea, Yacine Francis, Jane Jiang, Hayley Humphries, Steve Young, Zoe Newman, Ashu Sharma, Thomas Twitchett, Charlie Weston-Simons, and Dr Ayala Maurer-Prager, Ron Warmington, Manu Hanspal and Rebecca Linford for sharing their expertise. And to our delegates who engaged so thoughtfully with these challenging topics..

ACi’s community hopes that we can create workplaces where speaking up doesn’t require heroism, where investigations serve truth rather than predetermined conclusions, where doing the right thing doesn’t come at an unbearable personal cost, where we protect what matters most – human dignity, justice, and the most vulnerable among us.

The question isn’t whether we can afford to prioritise mental health in whistleblowing processes. We cannot afford not to.

#whistleblowing