A few weeks back I found myself traveling down a somewhat unfamiliar road, in the dark of night and with a thunderstorm quickly approaching. The rain and wind began pelting down, and my wipers could barely keep up with the heavy downpour. The glare from passing cars only added to the fun. “Thank goodness,” I thought. “As long as I can see the white line painted along the side of my lane, I know I’m still on my side of the road.”
Ethics & compliance reminds me of that white line. Ethics is knowing that staying in my lane is important. The white line helps keep me there, akin to a code of conduct, a policy, or an ethics reporting system that tells me that the organization wants to know when employees and the company at large is operating over that white line, so to speak. The ethics & compliance hotline is vastly important to giving employees confidence in their place in the organization, to knowing that they matter in the larger picture.
Amid the Wal-Mart/Mexican bribery scandal, reports state that someone inside the retailer with firsthand knowledge of the corrupt activity did in fact contact higher executives in the company with reports of wrongdoing. The whistleblower report solicited the attention of the top-most general counsel at Wal-Mart, enough to set off a preliminary investigation, which was apparently short-circuited later by the CEO.
Donna Boehme, a former chief ethics & compliance officer who now runs her own consultancy, sees two distinct failures in an event such as what has befallen Wal-Mart. Writing for the Whistleblowers Protection Blog, Donna says, “Creating and maintaining an internal reporting system requires a lot more than hiring a third party vendor, turning on the phone lines and hanging posters.” A two-dimensional hotline program she says, creates “a false sense of security” at the C-level and above.
Second, Donna makes a great point about the importance of how whistleblower calls are handled and how it reflects on the ethical standing and overall corporate culture of the organization. “If you really want a good barometer of a company’s culture, and the priority it places on accountability, transparency and ethical leadership, look no further than how internal whistleblower reports are treated. The enormous challenge for companies is how to turn this human knee-jerk response into a safe, transparent environment where internal reporting is valued (and not merely tolerated) and tips are expeditiously, confidentially and professionally investigated. Potential whistleblowers are nothing if not observant. Just as they notice misconduct, they also see what happens to those around them who raise their hands.”
Those are Donna’s two points, and here are three points of my own: One, how issues are escalated and how investigations are managed are crucial to both accountability and reputation. Second, employees must know that their concerns will be addressed. This is where follow-through via an incident management system and remediation must be front and center. Lastly, any form of whistleblower retaliation – which in my book includes an apathetic, “do-nothing” response – cannot be tolerated, if your reporting program is to remain trustworthy and viable to your cause.