An organization can’t claim zero tolerance for racial discrimination on the one hand and spend years building all-white leadership teams on the other, says HR executive Marcelle Moncrieffe‑Newman, PhD. She argues that, based on the lived experience of Black professionals, a “speak up” culture that tolerates microaggressions is one that Black employees simply won’t feel safe speaking to.
Compliance leaders depend on timely, honest reporting to keep organizations on the right side of law, reputation and ethics, yet many Black employees stay silent about racial discrimination even when policies, hotlines and training are in place. That silence is not evidence of low risk; it is often evidence of low trust in the very systems designed to surface misconduct.
In the research I did for my recent book, I heard the stories of Black professionals and their experiences of discrimination in organizations that all claimed to value equality, diversity and inclusion. Every participant reported experiencing racial discrimination at work, yet many had never used internal reporting channels or had done so only as a last resort, often after serious harm had already occurred. For compliance, risk and audit professionals, this should be a flashing red light about the limits of formal frameworks where lived reality does not match policy intent.
When “speak up” cultures exclude Black voices
In many organizations, “speak up” is promoted as a universal value, yet Black colleagues describe a very different calculus when deciding whether to report racism. Their hesitation is not only about individual incidents; it is about how race and culture interact with compliance processes that were rarely designed with them in mind.
Common patterns from my research include:
- Reporting channels that look neutral but are staffed, overseen and ultimately judged by people who have little understanding of anti‑Black racism, making it risky to trust their interpretations.
- Historic examples of Black colleagues who did raise concerns and were labeled “difficult,” sidelined or quietly exited, while perpetrators remained in their posts.
- Investigations that treat racism as a matter of interpersonal misunderstanding, rather than as conduct that exposes the organization to legal, regulatory and governance risk.
This should all be deeply concerning. A whistleblowing framework that works well for financial misconduct but fails for racial discrimination leaves a major class of risk unreported and unmanaged.
The hidden risk: backlash, racism denial and career damage
Black employees’ assessment of whether to report is shaped by three interlocking fears: retaliation, disbelief and long‑term career damage. These fears are rational responses to systemic patterns, not oversensitivity.
First, backlash is often subtle. Participants in my research described being taken off high‑profile projects, receiving lower performance ratings or being branded as “not a team player” after raising race concerns. These actions rarely appear in investigation files as direct reprisals, but they send a clear signal to others about the price of speaking up.
Second, racism denial is experienced as a form of secondary harm. Many Black professionals recounted carefully documenting incidents, only to be told that what they experienced was “not really racism” or that intent could not be proven. When decision‑makers underestimate or minimize race‑based harm, they do not just mishandle one case; they erode trust in the entire compliance framework for a whole demographic.
Third, career damage looms large. In sectors and organizations where Black representation in senior roles is already low, being perceived as “the one who complained” can feel like career suicide. My interviewees often weighed the potential benefits of reporting against the likelihood that senior leaders, who are often white and have never personally experienced racism at work, would empathize with their position. Too often, the conclusion was that the risks outweighed the chances of meaningful redress.
For compliance and audit professionals, this means that the highest‑risk issues, those involving culture, identity and bias, may be the least likely to be reported through formal channels.
When the system itself feels unsafe
An important finding from my research is that many Black employees do not distinguish between “culture” and “compliance” in the way programs are often structured. If the same organization that urges them to “speak up” has tolerated racial microaggressions, biased promotion practices or all‑white leadership for years, then the system itself appears unsafe, regardless of its policies.
This plays out in:
- Perceived organizational hypocrisy: Statements about zero tolerance for discrimination ring hollow when employees have seen racist behavior go unchallenged. This perceived gap between message and enforcement discourages reporting and encourages workarounds, such as seeking external legal advice or informal exits.
- Data that hides rather than reveals: Aggregated “bullying and harassment” categories or grievance statistics that do not track race can make racial discrimination effectively invisible at the board level, even when it is keenly felt on the ground.
From a governance standpoint, this creates a serious blind spot. Organizations may be confidently reporting low incident numbers, while missing the fact that their systems are failing to detect discrimination that exposes them to legal, regulatory and reputational risk. In other words, silence is not safety; it is often suppressed risk.
What compliance leaders can do differently
This work is becoming harder, not easier, in the current political climate. The Trump Administration has taken an openly hostile stance toward DEI, issuing executive orders to dismantle diversity infrastructure in federal agencies and to encourage investigations of corporate DEI as “unlawful discrimination.” The recently disclosed Equal Employment Opportunity Commission investigation into Nike’s hiring and promotion practices — examining whether its DEI objectives amount to discrimination against white employees — is widely seen as a test case for this strategy and a signal that high‑profile employers can be targeted for their equity commitments.
For Black employees, this reinforces a perception that the system is more interested in policing DEI than protecting them from racism, further chilling their willingness to report race‑based harms internally. The question for compliance leaders is not simply “How do we get more people to use our channels?” but “What would it take for Black colleagues to experience these channels as safe, credible and fair?” My research points to several practical shifts.
1. Treat racial discrimination as core compliance risk
Racial discrimination should sit alongside bribery, fraud, data protection and sanctions as a defined compliance risk with clear ownership, controls and escalation routes. This means:
- Explicitly recognizing race‑related misconduct, including racial harassment, exclusion and biased decision‑making, as violations of code of conduct and ethics policies.
- Integrating race into risk assessments, internal audits and board reports, rather than leaving it solely to HR or DEI teams.
- Ensuring whistleblowing and investigations frameworks explicitly reference protections for those raising race concerns and that these protections are monitored in practice, not only on paper.
When racial discrimination is framed as a core governance issue, not a sideline cultural issue, it changes who pays attention and what resources are deployed.
2. Build intersectional psychological safety into your program
Psychological safety is often discussed at the team‑building level, yet it is a structural requirement for effective whistleblowing systems, especially for marginalized groups. For Black colleagues, this means:
- Visible senior‑level sponsorship where leaders explicitly state that raising concerns about racism is welcome, necessary and career‑safe — and back this up with their own behavior.
- Investigation processes that are race‑literate, including trained investigators who understand systemic racism, microaggressions and the cumulative impact of repeated low‑level harms.
- Protection measures that look beyond direct reprisal to subtle career consequences, with regular reviews of post‑report performance ratings, assignments and promotion decisions for those who have raised concerns.
Without this intersectional lens, psychological safety can easily become something that majority‑group employees enjoy, while Black colleagues remain exposed.
3. Redesign reporting routes with Black employees, not just for them
Many of the Black professionals I interviewed felt that reporting systems had been designed around abstract notions of the “reasonable employee” and not around their lived experiences as Black people navigating race, culture and power. To correct this, compliance leaders can:
- Co‑design policies and processes with Black employee resource groups and external experts, asking specifically what would make reporting racism feel safer and more credible.
- Offer multiple confidential reporting channels — internal and external — and ensure that at least some options allow employees to speak with individuals trained and trusted on race issues.
- Stress‑test reporting and investigation processes using realistic race‑based scenarios, examining not just the formal steps but how people feel at each stage.
The aim is not to create a separate system for Black employees but to ensure that the existing system is truly accessible and trustworthy to those who currently have the most to lose by using it.
4. Use data to surface patterns, not to prove intent
Compliance functions are skilled at using data to detect patterns in financial and operational risk; the same rigor is needed for racial discrimination. Instead of waiting for a “perfect” complaint that proves racist intent beyond doubt, leaders should look for indicators like:
- Disparities in who uses whistleblowing channels by race, grade or location.
- Clusters of concerns about particular teams or leaders, even if each individual complaint is inconclusive.
- Links between low reporting rates and other data points,such as exit interviews, engagement survey comments or ethnicity pay gaps.
In my research, Black professionals often described “everyone knowing” where the racial problems were, without this knowledge ever translating into formal action. For compliance teams, the challenge is to convert informal, qualitative intelligence into structured insight that can trigger proportionate investigation and remediation.
From performative inclusion to credible accountability
Ultimately, Black colleagues do not feel safe reporting racial discrimination when they believe the system is more committed to reputational protection than to truth, repair and accountability. The question they quietly ask themselves is: “If I raise a concern, will this organization stand with me or will this be the beginning of the end of my career?”
For the compliance community, the challenge — and opportunity — is to ensure that the honest answer to that question is one that builds, rather than erodes, trust. That means moving beyond statements about zero tolerance to demonstrable patterns of action: investigations that are thorough and race‑literate, consequences that are proportionate and consistent, and structural changes that prevent recurrence.
My research in “One Step Forward Two Steps Black” shows that when organizations take racial discrimination seriously as a governance and compliance issue, Black employees are more willing to share the very information leaders need to manage risk and uphold their ethical obligations. Creating conditions where Black colleagues feel safe reporting is not a niche DEI concern; it is central to effective compliance, robust risk management and credible corporate integrity.


Marcelle Moncrieffe‑Newman, PhD, is an HR executive, speaker and consultant specializing in workplace culture, race and leadership. Her new book is titled “One Step Forward, Two Steps Black: Navigating Anti-Black Workplace Culture.” 







