There are many important predictors of corporate culture. Everyone laments the difficult in measuring a company’s culture. There are a few issues, however, that may be inconvertible as a predictor of a corporate culture.
How does a company react to a whistleblower? I am sure everyone is saying to themselves – well, we do not have that problem, we are committed to fair treatment of whistleblowers; in fact, we encourage people to raise concerns.
The proof is not in the broad statements of policy. A company with a corporate culture of compliance not only encourages and protects employees who raise concerns, but they seek out employees who raise concerns. In other words, they actively promote employees to raise concerns.
A company with a culture of encouragement will devote time to communicating a message that requesting employees to raise concerns. This may sound like a difference without a distinction but it is much more significant than you think.
A CEO who begins a town hall meeting with a personal statement requesting employees to raise concerns is a great start to a proactive culture of concern. Employees will react to such a statement and will raise the concerns, some to their supervisors and others on the hotline.
Once an employee has raised such a concern, the company’s proactive message has to be reinforced through the fair and attentive treatment of the whistleblower. For example, if the employee identifies himself or herself, a compliance officer should meet with the employee, thank the employee for raising the issue, and follow up on the issue quickly. The compliance staff should keep the employee informed as to the general status of the compliant or concern and continue to pursue the issue.
If the company substantiates the concern, there must be quick and effective remediation. As part of the process, the employee who raised the concern should be acknowledged and thanked for raising the issue.
A different course has to be followed if the concern is raised anonymously. The compliance officer should post responses, follow ups and questions concerning the complaint in the company’s hotline communications system. Instead of meeting with the employee, the compliance officer should use the communications system to keep the anonymous employee informed and seek additional information, if needed. Once the issue is resolved, assuming there is sufficient information to investigate, the employee who raised the issue should be apprised.
At some point in the process, the compliance officer should offer contact information in case the anonymous employee is willing to meet and discuss the matter. The employee should always have the option of coming forward.
Throughout the interactive process, the employee who has raised the concern has to be reassured about the lack of retaliation. In every communication with the employee, the company should reiterate its commitment to non-retaliation and to remind the employee to report such efforts if any occur.
Of course, my description of the investigative path is cursory and there can many nuances to the treatment of a whistleblower’s concern. In handling the request, confidentiality and careful investigation is critical. If the whistleblower learns that officials or employees have learned about the complaint and these individuals should not know about the concern, the company is likely to lose credibility with the whistleblower. Once that happens, it is hard, if not impossible, to regain the trust of the whistleblower.