“About that Confidential Employee Hotline …”
(An Open Letter to Boards, CEOs and other Interested Stakeholders)
Donna Boehme – Compliance Week – May 5, 2009
Every once in awhile I see something happening at a company that surprises me—in a good way—about its corporate approach to compliance and culture.
Most recently it was a comment from the audit committee chairman for a global foods company, describing the company’s practice of planting “false tips” within its organization to see whether those concerns will be reported and rise to the top. It was similar to another company that routinely drops complaints into its confidential hotline to verify the performance of its third-party provider in different parts of the world. After many years in the trenches of compliance and ethics, and as an observer of how organizations can sometimes lack political will to “walk the talk,” these developments are heartening.
That said, people at the very top of an organization—whether they’re in the boardroom or the C-suite—always have a difficult time understanding what really happens on the ground when an employee decides to use the company’s confidential hotline to report suspected wrongdoing. (And make no mistake, for almost all employees, reporting a complaint on the hotline is a very big step.) In fact, once a call is logged into the system, there are 1,001 ways the process can go awry. (I won’t even address all the ways employees can be discouraged from making that important call in the first place; that’s a topic for another day.)
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