But for others, new rules introduced by the FCA in 2016 have been the real driving force. As a result, many have fast-tracked the introduction of a compliant speak up service at short notice.

In our experience, companies simply 'ticking the box' receive few (if any) speak up reports. And, as any compliance or legal team will know, silence is rarely a positive signal.

Effective speak up procedures help banks (and other organisations) identify serious conduct issues early on. This enables compliance and legal teams to investigate and tackle them internally before they become serious enough to attract the attention of regulators and the media.

As such, they must be at the centre – not the periphery – of a bank's culture, ethics and processes. This is supported by our research late last year into over 100 businesses (including leading financial services companies) using external speak up services.

Over the past year, 20% of respondents said it had successfully helped recover company assets following a whistleblowing report; 17% said reports had led to the business launching criminal proceedings; and 62% had improved their internal controls as a result of reports received.

As you might expect, a successful speak up service is dependent on several factors. Employee trust, effective promotion, the presence of a 'listen up' management culture and evidence that the company takes reports seriously can all have a major impact on reports.

Unfortunately, our research suggested that the critical role of managers is being overlooked, with only 17% of organisations training them how to handle a speak up report. The conduct of senior executives and middle management plays a major role in shaping employees' perceptions about the 'safety' of speaking up.

In an industry like banking – where long-established, traditional cultures often exist – nurturing openness and trust is especially important.

Information is often provided on condition of anonymity (for instance, two-thirds of people using our service chose to be anonymous to their employer in 2017). A clear commitment to respecting this wish is critical in building trust among employees in order for them to reveal crucial and otherwise hidden information.

Some of the UK's leading financial institutions are already setting the standard, treating their speak up programme as a key business asset – and reporting against it accordingly. This involves moving beyond simple reporting measures – such as 'number of speak up reports received' (a metric used by 51% of businesses surveyed) – to more sophisticated analysis of substantiation rates, employee feedback, report themes and the outcomes they bring about.

It is, of course, right that banks maintain strong principles of privacy. However, it is also right that speaking up is increasingly welcomed as an opportunity to tackle cultural failings – and prevent the issues of the past from reoccurring. As the FCA focuses its attention on the effectiveness of banks' whistleblowing arrangements, now is the time to give your programme a new year health check.