No Result
View All Result
SUBSCRIBE | NO FEES, NO PAYWALLS
MANAGE MY SUBSCRIPTION
NEWSLETTER
Corporate Compliance Insights
  • Home
  • About
    • About CCI
    • CCI Magazine
    • Writing for CCI
    • Career Connection
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Library
    • Download Whitepapers & Reports
    • Download eBooks
    • New: Living Your Best Compliance Life by Mary Shirley
    • New: Ethics and Compliance for Humans by Adam Balfour
    • 2021: Raise Your Game, Not Your Voice by Lentini-Walker & Tschida
    • CCI Press & Compliance Bookshelf
  • Podcasts
    • Great Women in Compliance
    • Unless: The Podcast (Hemma Lomax)
  • Research
  • Webinars
    • Upcoming
  • Events
  • Subscribe
Jump to a Section
  • At the Office
    • Ethics
    • HR Compliance
    • Leadership & Career
    • Well-Being at Work
  • Compliance & Risk
    • Compliance
    • FCPA
    • Fraud
    • Risk
  • Finserv & Audit
    • Financial Services
    • Internal Audit
  • Governance
    • ESG
    • Getting Governance Right
  • Infosec
    • Cybersecurity
    • Data Privacy
  • Opinion
    • Adam Balfour
    • Jim DeLoach
    • Mary Shirley
    • Yan Tougas
No Result
View All Result
Corporate Compliance Insights
Home Governance

Avenues for Reporting Employee Concerns

by Michael Volkov
December 29, 2014
in Governance
Avenues for Reporting Employee Concerns

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.


Previous Post

Asia Pacific Anti-Corruption Rankings for 2014

Next Post

What FCPA Enforcement was Thinking in 2014

Michael Volkov

Michael Volkov

Michael-Volkov-leclairryan Michael Volkov is the CEO of The Volkov Law Group LLC, where he provides compliance, internal investigation and white collar defense services.  He can be reached at mvolkov@volkovlaw.com. Michael has extensive experience representing clients on matters involving the Foreign Corrupt Practices Act, the UK Bribery Act, money laundering, Office of Foreign Asset Control (OFAC), export controls, sanctions and International Traffic in Arms, False Claims Act, Congressional investigations, online gambling and regulatory enforcement issues. Michael served for more than 17 years as a federal prosecutor in the U.S. Attorney’s Office in the District of Columbia; for five years as the Chief Crime and Terrorism Counsel for the Senate Judiciary Committee, and Chief Crime, Terrorism and Homeland Security Counsel for the Senate and House Judiciary Committees; and as a Trial Attorney in the Antitrust Division of the U.S. Department of Justice. Michael also maintains a well-known blog: Corruption Crime & Compliance, which is frequently cited by anti-corruption professionals and professionals in the compliance industry.

Related Posts

klarna app germany

UK Looks to Set New Global Standard With BNPL Regulation

by John Byrne
July 17, 2025

With their reliance on late fees, buy-now-pay-later services seem designed to take advantage of consumers

bull statue on wall street

Is Recency Bias Undermining Your Fiduciary Duty?

by Steven Abernathy
July 17, 2025

Plan sponsors have a responsibility to keep participants informed about risks of investing & the potential impact of changing market...

get out of jail free card

Rare Declinations by DOJ’s National Security Division Demonstrate Potential Benefits of Voluntary Disclosure — but Could Obscure the Risks

by Justin Weitz, Loyaan Egal, Katelyn Hilferty and Moshe Klein
July 16, 2025

In a recent speech, Matthew R. Galeotti, the head of the DOJ’s Criminal Division, discussed changes in how the DOJ...

robot waiting for job interview

If AI Can Easily Game Hiring Processes, Maybe It’s Time to Rethink What You’re Looking For

by Vera Cherepanova
July 15, 2025

Using AI to prepare for an interview is OK, but what about using it to perform?

Next Post
What FCPA Enforcement was Thinking in 2014

What FCPA Enforcement was Thinking in 2014

No Result
View All Result

Privacy Policy | AI Policy

Founded in 2010, CCI is the web’s premier global independent news source for compliance, ethics, risk and information security. 

Got a news tip? Get in touch. Want a weekly round-up in your inbox? Sign up for free. No subscription fees, no paywalls. 

Follow Us

Browse Topics:

  • CCI Press
  • Compliance
  • Compliance Podcasts
  • Cybersecurity
  • Data Privacy
  • eBooks Published by CCI
  • Ethics
  • FCPA
  • Featured
  • Financial Services
  • Fraud
  • Governance
  • GRC Vendor News
  • HR Compliance
  • Internal Audit
  • Leadership and Career
  • On Demand Webinars
  • Opinion
  • Research
  • Resource Library
  • Risk
  • Uncategorized
  • Videos
  • Webinars
  • Well-Being
  • Whitepapers

© 2025 Corporate Compliance Insights

Welcome to CCI. This site uses cookies. Please click OK to accept. Privacy Policy
Cookie settingsACCEPT
Manage consent

Privacy Overview

This website uses cookies to improve your experience while you navigate through the website. Out of these, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyze and understand how you use this website. These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may affect your browsing experience.
Necessary
Always Enabled
Necessary cookies are absolutely essential for the website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.
CookieDurationDescription
cookielawinfo-checbox-analytics11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checbox-functional11 monthsThe cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checbox-others11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-necessary11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-performance11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
viewed_cookie_policy11 monthsThe cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.
Functional
Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features.
Performance
Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.
Analytics
Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc.
Advertisement
Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customized ads.
Others
Other uncategorized cookies are those that are being analyzed and have not been classified into a category as yet.
SAVE & ACCEPT
No Result
View All Result
  • Home
  • About
    • About CCI
    • CCI Magazine
    • Writing for CCI
    • Career Connection
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Library
    • Download Whitepapers & Reports
    • Download eBooks
    • New: Living Your Best Compliance Life by Mary Shirley
    • New: Ethics and Compliance for Humans by Adam Balfour
    • 2021: Raise Your Game, Not Your Voice by Lentini-Walker & Tschida
    • CCI Press & Compliance Bookshelf
  • Podcasts
    • Great Women in Compliance
    • Unless: The Podcast (Hemma Lomax)
  • Research
  • Webinars
    • Upcoming
  • Events
  • Subscribe

© 2025 Corporate Compliance Insights