Do you believe that an ethics hotline is part of your compliance program and helps to drive your ethical culture? Do you see value in having a neutral third party run your ethics hotline program? If you said yes to both these questions, you’re in the majority, and that’s a good thing. Still, there are those who just don’t get it.
In a recent sales and marketing session, we were discussing how some prospects dismiss the need for an ethics hotline. We’ve heard comments like, “an ethics hotline doesn’t fit within our company culture,” and “a hotline service doesn’t have any benefit to our organization.” Questions comes to mind such as, so what kind of culture do they have? Do they think that they are already “too ethical” to need a hotline? Will the reports they intake internally will have any substantive value? How about their employees? Are they comfortable with airing their suspicions and discussing their issues face to face?
Some organizations feel that if they receive only a few calls a year through their hotline, everything must be a-ok. No problems. We’re all ethical people, all the time. No rogue employees here. Cue the ostrich in the sandpit. That’s narrow-minded thinking at best.
Of course you don’t want your ethics hotline to ring off the hook, but you should want to detect misconduct when it occurs. It’s much more in the meaning behind the message than the letter of the law. When you give your employees a way to file a report – anonymously and in confidence that it will reach the appropriate set of eyes – you’re telling your workforce that you want blue skies, but you aren’t naive in believing just because your policies say ‘don’t do something wrong’, nobody will. You’re letting them know that their voice matters, and that you have confidence in them. And, it’s been proven that an ethical environment boosts employee reporting.
Some organizations believe that their hotline program is just an 800 number, like a 9-1-1 system only to be used in dire emergencies. It’s what goes on behind the scenes that sets an outsourced hotline system apart from an internal-only reporting system. Think about the resources that you’ll have to allot to an internal-only system. Will you staff it only during working hours? How about your non-English speaking or internationally based employees? Will the internal hotline meet your local whistleblower laws (like SOX, Dodd-Frank and the EU Whistleblower Guidelines)? And what do you do with the reports once they come in, as far as dissemination, escalation, investigation, etc.? Is the data truly secure – or is it kept in a file cabinet or on someone’s desktop?
Perhaps most important is the notion of employee confidentiality. Very few people like to “blow the whistle.” Look at what happened to someone like Amy Block Joy after she uncovered misappropriations at the university where she taught. But employees almost always want to do what’s right. They feel that letting someone “get away with it” erodes their own moral code as well as potentially damaging their job security.
Another reason for the third-party hotline provider option versus the internal-only approach: not to cut down anyone successfully operating an internal program, but a third-party hotline has a level of credibility that far exceeds what you might market internally. When it’s promoted and preached throughout your organization, coupled with a solid Code of Conduct, policies on specific areas of concern and training that employees can understand and retain, your entire ethics program gains a more positive reputation. Unlike the ostrich, it can stand tall and proud with its head held high.