This article was republished with permission from Michael Volkov’s blog, Corruption, Crime & Compliance.
We all like to make things more complex or difficult than they need to be. Consider that a life lesson that we can share with our children, assuming they are even listening to us these days.
Compliance is a field that is easy to make overly complex. The trick is to be effective and to keep it simple.
I hear a frequent debate on whether a company should have one or two avenues for reporting employee concerns or hotlines, or maintain multiple avenues. The debate reminds me of a dog chasing its own tail. There never will be a satisfactory answer.
One the one hand, those who argue against multiple avenues for reporting employee concerns cite the diminution of a reporting avenue’s “brand.”
Opponents of this view usually point to the fact that the more avenues there are, the more likely an employee is going to use one of them, and that is all that matters – getting the complaint in the system.
The argument seems to boil down to whether or not a “brand” is more important than multiple possibilities. I find the argument distracting.
A Chief Compliance Officer has to look at the company’s culture and decide, in consultation with other stakeholders, what approach is likely to be most productive. Everyone agrees that the goal is to encourage employees to report concerns. (Of course, not every concern.)
The trick is to examine each possible avenue and make some decisions as to which ones might work well. No surveys, studies or other fancy-dancy costly reports are needed on this issue. Common sense sometimes is the most effective tool that a CCO can use.
An open-door policy is certainly an important avenue – whether it is to a direct supervisor, a skip supervisor, a senior manager or the Board itself. Such direct reporting should always be encouraged as one important avenue.
A second avenue is an ethics and compliance organization – an internal committee responsible for the oversight and management of the ethics and compliance function should be open to hearing employee concerns.
Employees logically look to the Human Resources office to report their concerns, even when the concern does not relate to an ethics and compliance issue. HR staff should be familiar with receiving such concerns and responding to the employee.
For some employees, anonymity and language capability is an important consideration in deciding where to raise a concern. Anonymity can be important for an employee who wants to report a concern and fears retaliation. Language capability is important for obvious reasons.
Many employees also cite the importance of reporting a concern to a third-party hotline service (e.g. NAVEX Global). Some employees believe (rightly or wrongly does not matter) that a third-party hotline is better than an internally maintained hotline system.
Companies also need to examine some of the new technologies for encouraging reporting such as online chat functions (which should protect the employee’s identity if needed). Web-reporting systems are much more common in the workplace, but can differ on whether the system uses intranet or public Internet access.
Whatever avenues are available, companies have to pick and choose those systems that will be embraced by the workforce and ensure that the avenues integrate into an effective triage/screening process and quick follow-up for investigation. Once the complement of avenues is picked, then companies have to design a campaign to promote the availability of such avenues for employees to use.
After a set of reporting avenues are in place, the system should be measured and monitored to see what avenues are working and what avenues are not. Again, real life results will guide the eventual design of the employee concern system using common sense as a guidepost.