Raw hotline metrics rarely tell a nuanced story and can be easily misinterpreted — a decline in reports might suggest reduced misconduct but could also indicate weakening speak-up culture. Gartner’s Nicholas Sworek outlines how compliance leaders can use data visualization and storytelling to help boards grasp the significance of trends.
The recent dismissal of Nestlé CEO Laurent Freixe following an investigation into an undisclosed relationship with a direct subordinate has put a spotlight on the critical role whistleblower hotlines play in surfacing misconduct, even at the highest levels of leadership. The case, which began with anonymous reports submitted through Nestlé’s Speak Up hotline, underscores the importance of robust reporting mechanisms and the need for compliance leaders to communicate hotline metrics to the board in ways that drive purposeful oversight and action.
Inventory and analyze existing hotline data
The first step is to create a comprehensive inventory of all hotline data sources, whether managed by a vendor or internally. Most organizations rely on vendors for hotline services, which means compliance leaders should work closely with these partners to understand standard metrics and explore opportunities for deeper analysis. For organizations managing their own hotlines, tracking data like the number of reports, timing, risk category, escalation rate and substantiation rates is crucial.
Beyond aggregate metrics, compliance leaders should analyze demographic cuts of the data, such as by business unit, location or time period. This approach can reveal patterns that may indicate underlying risks, as well as track the effectiveness of interventions. For example, according to company data, Nestlé’s Speak Up hotline received 3,218 complaints in 2024, a 12% increase over the previous year, but saw a 7% decrease in substantiated complaints, leading to 119 dismissals. Such insights can help boards understand not just the volume but the impact of whistleblower activity.
Expand the scope of data inputs
In addition to traditional structured data analysis, AI technologies now offer significant opportunities for compliance teams to analyze semi-structured and unstructured data, such as audit findings, investigations’ reports, scanned documents or images, employee questions, social media posts and interactions with compliance facilities.
Leveraging AI-driven analytics enables organizations to identify pockets of potential misconduct before actual cases are reported, by drawing actionable insights from behavioral patterns and sentiment analysis. For example, analysis of the types of questions employees are asking and their engagement with compliance resources can provide intelligence on emerging risks and behaviors, allowing for proactive interventions before misconduct occurs.
A balanced approach that combines traditional metrics with advanced analytics will enable organizations to maximize the value of their hotline data while mitigating the risks associated with emerging technologies.
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Read moreDetailsAlign hotline metrics with board priorities
Once the available data is understood, compliance and ethics leaders must prioritize what to report based on the board’s strategic objectives. Boards are increasingly focused on investments in new products, AI, and mergers and acquisitions, according to Gartner’s 2025 board of directors survey. By aligning hotline metrics with these priorities, CCOs ensure that the board receives information that is directly relevant to its oversight responsibilities.
For instance, if the board is concerned about risks to a major investment, compliance should highlight hotline metrics related to financial misconduct or fraud in the relevant business unit or geography. This targeted reporting enables directors to proactively address risks before they escalate, as was the case with Nestlé, where the board acted swiftly on whistleblower reports implicating the CEO.
Use data visualization and storytelling to drive engagement
Data alone rarely tells the full story. Compliance leaders must transform raw hotline metrics into compelling narratives using data visualization and context. This approach helps board members quickly grasp the significance of trends and make informed decisions. Storytelling is especially important for hotline data, which can be easily misinterpreted. For example, a decline in reports might suggest reduced misconduct but could also indicate a weakening speak-up culture.
A three-part storytelling approach ensures that compliance insights are not only heard but acted upon. The components of this framework include:
- Tailoring the message to the board’s context.
- Presenting data visually.
- Crafting a narrative that resonates personally with board members.
The value of transparent and timely hotline reporting
The Nestlé case illustrates how effective hotline reporting can empower boards to address even the most sensitive issues. Speak Up, Nestlé’s independent global reporting channel, allowed employees to confidentially flag concerns about the CEO’s conduct. The board responded with a rigorous investigation, demonstrating best-in-class governance and the importance of timely, transparent action.
Nestlé’s process also highlights best practices for managing hotline complaints: prompt acknowledgment, clear escalation criteria, thorough investigation and communication of outcomes. These steps, combined with regular reporting of metrics such as complaint volume, substantiation rates, and disciplinary actions, provide the board with a holistic view of organizational risk.
A call to action for compliance leaders
As regulatory scrutiny increases, exemplified by the DOJ’s expanded corporate whistleblower awards pilot program, boards will demand even greater transparency and insight from compliance. By inventorying available data, aligning metrics with board priorities and using storytelling to bring the data to life, compliance leaders can ensure their hotline reporting drives real impact.
Nicholas Sworek is a director of advisory within Gartner’s legal and compliance practice. He focuses on advising chief compliance officers and their teams on a range of issues spanning innovative technology applications, third party risk management and effective compliance program management. 
