“A company can go to extraordinary lengths to create and manage a first-in-class antibribery compliance program. It can work to send the right internal messages, nurture open communications, and be vigilant in upholding its clearly stated standards. And still, the compliance team might first read about an internal problem in The New York Times or in a letter from the U.S. Department of Justice.”
That’s how Alexandra Wrage, a compliance and anti-corruption consultant, begins a discussion about internal compliance reporting and the approach companies should take to make sure employees know about and use their internal ethics hotlines.
And she’s right, of course. If your employees can’t or won’t report an incident or issue through your internal hotline, they just might go somewhere else, like the SEC. It takes more than just having a hotline – it takes a cross-enterprise program that promotes ethical behavior, speaking up and doing the right thing. Sounds easy, doesn’t it?
It’s nice to see that Wrage’s communication has two essentials of a good reporting initiative. If you don’t tell employees the why’s and how’s behind reporting – why filing a report is important to the safety and success of both the employee and the company, and exactly how a report is filed and processed – you can’t really expect much out of your hotline.
We’ve built our solutions, including anonymous employee hotlines, around the premise of “protect, detect & correct.” The way Wrage describes her ideas of reporting best practices could be summarized as “act, respect and protect.” What it essentially boils down to is this: Reported incidents must be investigated promptly, the confidentiality of the reporter must be treated with the utmost sincerity and seriousness, and follow-up must take place as well as be communicated to the employee who filed the report and the larger employee community.
Number eight on the list is by far the most difficult: Deal with the aftermath. That means ensuring that those who come forward are never, ever retaliated against and the proper escalation takes place so that the whistleblower’s actions have meaning. After all, your employees do want to talk to you. They want to do the right thing. So make sure they can – and do.