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Fostering the right environment
Organizations must develop and then update regularly comprehensive whistleblowing processes that set out how individuals can report actions that they believe are problematic. This includes how they can disclose these activities and to whom. An equally important part of the process is training and information. It is not enough to set out a policy and bury it inside a rarely-seen or hard-to-access handbook – instead companies should conduct firm-wide training on a recurring basis, so that all employees know their rights under the whistleblowing policy.
It is the responsibility of the firm’s leadership to ensure that whistleblowing programs are seen as more than just window dressing. Integrating a whistleblowing policy into a firm’s culture and values in the longer-term is important. Employees feel safe when there is a comprehensive culture of integrity inside the organization and people know that the company is committed to these values.
A critical related concept is the ability for a company to “listen down” – to actively be able to receive input and feedback from layers below executive management. This helps foster an environment where employees feel comfortable “speaking up” when they see things they believe go against the values of the company. Indeed, organizations should promote a culture that treats whistleblowing as a duty and responsibility where wrongdoing or unethical behavior is occurring.
Fostering security
Effective whistleblowing programs should become self-perpetuating. Employees who have positive experiences with the program will serve as ambassadors for future use of the system.
A common approach to handling complaints is the creation of a hotline where employees can file a complaint. This can be a good start, but it is only the beginning. Consideration must also be given to who reviews the information. A neutral board must be deployed, with both the expertise to understand legal and moral requirements, and the gravitas to make recommendations that are taken seriously. This could include external partners, depending on the industry.
Communication throughout the process is often a complicating factor. In order to have a “neutral” investigation of the facts, many processes are necessarily opaque. While privacy for both the accused and the accuser are important, any whistleblowing process should have standardized ways of reporting back to the original complainant. An accuser should be trained to know ideally before they make a complaint or when making their first call, when and how they will be informed about the outcome of the case.
Whistleblowers have two common concerns when they make their case – that their complaint will be ignored or that they will face consequences and retaliation for blowing the whistle. This is validated by the EY Global Integrity Report 2020, with 53% of respondents who had reported an issue stating they felt under pressure not to report. This was not universal, as respondents reporting pressure varied from 83% in Japan to 38% in Mexico. Local context and customs – as ever – matter.
Keeping the whistleblower informed during the process can help with the fears of being ignored, while organizations can allay fears of retaliation by publicizing protections that are in place for whistleblowers and highlighting cases where action brought to light by a whistleblower has led to reform.