This post is the product of an interview with Grant Stevens, Head of Sales, Expolink Europe Ltd http://expolink.co.uk/
What are the main considerations for employers when setting up an externally-managed hotline for the first time?
Like any worthwhile venture, whistleblowing hotlines benefit from forethought and planning. A great deal will depend on the size of your business, the nature of your operations, the countries you operate in and what risks your business and employees are exposed to. We advise clients to consider not only their current risk profile but also what the shape of their business might be within the next five to ten years. International data protection laws vary enormously (and some border on the positively cryptic) so a full analysis of the countries you operate in and intend to operate in, is vital.
A second geographical consideration is the language-related services you require; again taking into account how the profile of your employees and business might change. Where possible, live translation services should be offered as it is not always possible for a caller to make contact at a later point. The service must be as accessible as possible, ideally including 24/7 availability and where country law allows, it should be confidential.
Employers should also seek to identify the goals for their hotline, since this may affect its final form. For most, it is a combination of protecting employees, ensuring good governance, compliance with legislation such as the Bribery Act 2010 or requirements from industry regulators like the FCA, and mitigating risk to their business in general.
If the hotline will complement current internal reporting channels, communication of these processes and employee expectations must be managed well. Some clients opt to have separate lines for HR-related grievances and reports of, say, financial misdemeanour and although nothing terminal usually happens if the two are confused by the employee it is still preferable that guidance is issued as to how to go forwards in any given case.
Employers need to consider the potential barriers to use of the whistleblowing hotline and how these will be overcome. Are there any local laws, customs or cultural considerations that should be considered? Certainly, there are territories, particularly post-communist countries or those that have experienced aggressive regime change where expressing concerns about potentially unlawful colleague behaviour would be a very sensitive matter indeed. In these scenarios, communication needs to be handled carefully and even terminology may be adjusted, using “Speak-up” rather than “Whistle Blowing” for example.
How should businesses assign responsibilities for implementing and managing the hotline?
Again, this is very much dependent on the structure and scope of your business. Some organisations have a whole department dealing with internal audit, compliance and ethics-related activity. Others may have only an Ethics Champion or it may fall under the remit of Human Resources.
After roll-out, the success of the hotline very much depends on engagement and communication with the process. We advise employers to enlist support from different centres of the business, whether that is departmental or geographical. All stakeholders must understand the importance of their role in the success of the hotline and be accountable. The key issue here is substance rather than form – it does not much matter where responsibilities lie so long as the relevant person has both the will and the internal clout to make others act appropriately when the whistle is blown.
How can businesses ensure the hotline is communicated and marketed effectively throughout the business?
Assigning responsibility for the overall communication of the hotline to one of your Ethics Champions is a good idea, as is making awareness of the hotline part of staff inductions. Information given at this stage, however, is likely to be only part of a whole raft of other important resources the new starter is exposed to at the same time so, while this stage is relevant, other tools should be used to ensure awareness remains fresh.
Over the years we have noted success with collateral such as mouse mats and pens with the hotline details inscribed. Posters can be another marketing tool but they should ideally stand out from the rest of the notice board. Wallet cards (about the size of a credit card) are one of the most effective tools as staff can keep these as a handy reminder.
Company intranets are an obvious and effective platform but again, visibility is key, so try not to lose your hotline processes in reams of small print. If you are unsure of awareness levels or concerned that there may be barriers to usage, a simple anonymous survey can help.