Just like many other tools used in compliance, a compliance and ethics hotline is only as useful as the knowledge and training of the individuals using it allow it to be.
Here we discuss some common issues with hotlines, and what you can do to solve them.
FINDING A BALANCE
If no one in the company knows how to access the system, or if people are afraid to use it, then it will be underutilised and ineffective. On the other hand, if the purpose of the hotline is not made clear or if users don’t know what constitutes a compliance risk, then it can quickly become a place for employees to vent office gossip and local personnel issues to someone outside their office, putting strain on a global compliance team’s time and resources.
Striking the balance between these two scenarios is difficult. It takes dedication and training to build up enough awareness and trust in a hotline for it to be an effective tool, but when call numbers start to grow and the reports expand beyond the intended scope even simple attempts to clarify the hotline’s purpose can have a devastating impact on its use. If people are unsure whether they should call they will often choose not to report rather than risk being told that that they are doing so in error.
However, there is a simple solution to this problem: having a hotline program that can divert and channel reported issues to the appropriate people within the company, rather than having a single choke point. This way the workload is evenly distributed, allowing the compliance team to focus its time and efforts on the serious calls while the local human resources team can deal with concerns within their purview.
DETERMINING THE INTENT OF REPORTS
Another concern when dealing with hotlines is distinguishing the intent of the reporting.
Rarely do people reach out regarding issues they’ve seen because of a benevolence and zeal for protecting the company. Instead, reports are often made for self-preservation – the reporter fears that the issue could not just impact the company at large, but could also impact them and their livelihood.
Other reports are made out of spite or a vendetta against a fellow worker. While this motive can lead to a high risk of hyperbole or fabrication of facts (which are serious issues that must be dealt with as they are ethics concerns in and of themselves), there may be valid compliance issues. Just because someone is acting out of ill will towards another, the issues they raise should not be immediately invalidated. Effort has to be made to ensure that all calls are dealt with appropriately.
Once employees are properly trained and have gained confidence in the hotline, their trust in the hotline will ebb and flow and will require effort to maintain.
One of the best ways to maintain confidence in the hotline is to demonstrate that it works. Letting reporters know that steps are being taken, and informing them soon after the report was made, will build confidence that reports are taken seriously and acted on.
Providing high-level information about successful reports (or ‘success stories’) in a newsletter or other company-wide communication will further build confidence. If people who would usually not be inclined to use the tool see its successes they can see that it will likely be worth making a report if they ever need to do so.
Ideally reporting would always be done locally and in person, but in reality the more opportunities and avenues that are provided to employees to report (many of which can be anonymous) the more likely it is that issues will be dealt with in a timely manner, and the company will be better off for it.
Helping to properly distribute the subsequent workload through compliance, human resources, legal or other relevant teams will also grow the effectiveness of the hotline.
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