28any person that has disclosed, or intends to disclose, a reportable concern:
- (a) to a firm; or
- (b) to the FCA or the PRA; or
- (c) in accordance with Part 4A (Protected Disclosures) of the Employment Rights Act 1996.
A person is not necessarily a whistleblower if they use a channel other than the internal arrangements set out in SYSC 18.3.