It is often through whistleblower hotlines that employers find out where they have gaps in their policies and training. Several best practices can be adopted to improve a hotline program.
- Earn employee trust. It is management’s responsibility to instill confidence in employees by demonstrating commitment to ethical practice and to offer a variety of interactive methods for reporting employee concerns. Without employee buy-in, the company will not have a functional reporting program. Communicate commitment to ethics and compliance frequently, and find ways to reward ethical behavior. When employees see that management values an ethical culture, they will trust the company to take their reports of misconduct seriously.
- Offer a telephone and web-based hotline service. Many reporting programs now have web-based, text-based and other electronic reporting options, in addition to reporting via the telephone. Ensure that in each case all information is gathered to resolve allegations and initiate investigations while protecting the identity of the anonymous reporter.
- Ensure timely escalation and dissemination. Company executives and hotline managers should agree on a list of specific topics that require immediate escalation and cannot wait until the next business day. Reports that warrant escalation within the next 24 hours involve issues of violence, fraud, release of proprietary information, falsification of company records and theft. It is crucial that the escalation process includes a document of key personnel to contact, how they can be reached and how to manage high-risk reports.
Additionally, it is in the company’s best interest to set dissemination rules prior to implementing the hotline to strengthen the credibility of the program. Have a protocol in place for what should happen if someone in the usual dissemination stream is mentioned in a report. Have reports sent to the ethics or compliance offer, as well as the individual assigned to the investigation to ensure complaints are not mishandled or overlooked, but have a list of backups in place. This method serves as a protective measure to prevent a report from being sent to the accused party. Adopting dissemination best practices will minimize the risk of an investigation not being carried out in a timely manner or at all.
- Single-hotline and third-party hotline considerations. While some organizations have had multiple hotlines for different types of issues, this can burden and confuse employees. They are more likely to become discouraged when the hotline turns them away if, for example, an employee complaint is regarding a discrimination issue and the hotline manages all but discrimination topics. A single-hotline approach relieves this burden. Furthermore, third-party hotline providers can automatically forward numbers from previously separate hotlines to a consolidated number, as well as implement a distribution process that ensures the correct people continue to receive complaints regarding their areas of responsibility. Third-party hotlines have well-established processes in place for capturing and disseminating reports. They have trained staff to assist with employee concerns, with the added benefit of reassuring employees that their anonymity is safeguarded. A third-party hotline provider finally ensures there is no bias around what qualifies as a time-sensitive issue.
A whistleblower hotline reporting program is a crucial part of a best practices ethics and compliance program. Companies must make sure their hotlines are consistently updated and audited to provide the best possible options for employees and protecting the business in case something goes wrong.