May a whistleblower report a violation committed by one of the commission members?

ANSWER

Although the likelihood of such a situation occurring is small, the whistleblower reporting procedure should also provide for a course of action in the event that

the report concerns a violation committed (potentially) by one of the commission members. A possible solution might be a situation where:

• the initial review, or rather the receipt of the report itself, would be collective, in the sense that all new reports would be reviewed by the entire commission, after which they would be divided among the three individual commission members. The aim here is to prevent a situation where a given report is reviewed solely by the commission member to whom it relates, as there is a risk that such a report would not receive proper attention;
• the procedure would provide that such a report (relating to one of the commission members) is promptly forwarded to an appropriate person outside the commission.

This is, of course, only an example scenario.