A whistleblowing hotline is a channel that allows employees and others to confidentially alert an organisation about suspicions of misconduct. It is an important tool for reducing risks and building trust as it enables managers to detect and act on possible misconduct at an early stage. Whistleblowing hotlines also perform a preventive role as their mere existence can make people think twice about committing acts of fraud, corruption, harassment and other improper practices. Whistleblowing hotlines were placed firmly in the spotlight in 2002, when the Sarbanes-Oxley Act required all listed American companies to have a channel and a process in place for whistleblowing. At that time the regular platform was phone and voice. This is why the term whistleblowing hotline is still used today, even though it is just as likely to describe a digital solution and a broader whistleblowing system. In this post we will describe:
- What kinds of whistleblowing hotlines exist
- The components of a whistleblowing hotline system
- Four critical factors for a successful organisational whistleblowing hotline
What kinds of whistleblowing hotlines exist?
- Digital whistleblowing hotlines
Digital whistleblowing hotlines are channels that allow people to blow the whistle online, through a web-based whistleblowing hotline service. Their main advantage is that they very easily allow whistleblower anonymity, a key factor for encouraging people to report suspicions without the fear of repercussion. They also allow a whistleblower to attach files, both text and images, as potential evidential material. Online whistleblowing hotlines also keep all data in one place, and most importantly, secure, in full compliance with GDPR and other applicable laws. Compliance can be a built-in part of the whistleblowing hotline software, making the burden of compliance somewhat lighter for the organisation. Finally, whistleblower case management and user activity can be logged as an automatic functionality within digital whistleblowing hotlines.
- Phone-based whistleblowing hotlines
Phone-based whistleblowing hotlines allow people to blow the whistle by making a regular phone call to the appointed whistleblowing champion. While, like digital channels, they can be made available 24/7/365 and allow some amount of anonymity, they are less secure as the information cannot be encrypted all the way from the whistleblower to the receiver of the message. Phone-based whistleblowing hotlines are less cost-efficient because they do not allow integrated case follow-up, meaning that information will have to be manually logged. Since they do not allow a range of devices to be used, they are also less user-friendly. However, in countries where Internet access is not widespread, or for employee groups that are not used to writing, phone-based whistleblowing hotlines are a good option.
- Face-to-face whistleblowing
Face-to-face whistleblowing is an “open door” option rather than a traditional whistleblowing hotline. It is a way for a manager or other superior to show the whistleblower that their concerns are being taken seriously, and that the information should be reported to those who have the responsibility and skills for dealing with whistleblowing cases. While the whistleblower receives immediate feedback, there is no automatic data protection and no efficient case follow-up. Clearly, there is no anonymity in this kind of whistleblowing, requiring a huge amount of trust between the parties concerned, a clear disadvantage compared with other whistleblowing hotlines.
- Whistleblower e-mail address and inbox
Whistleblower e-mail address and inbox is another form of whistleblowing hotline that some organisations opt for. While they are simple and inexpensive to set up, they come with significant risks. E-mails cannot be fully encrypted so data is insecure, placing the organisation at risk of non-compliance with legal requirements. Messages may also be read and tampered with by unauthorised parties as they pass between hands. This lack of security significantly reduces the trust that potential whistleblowers will have in such a form of whistleblowing hotline, thus reducing the likelihood that they will report concerns. Finally, as with telephone reporting, e-mail whistleblowing does not come with integrated case follow-up and management, making this not only a risky but also an inefficient form of whistleblowing hotline.
What is a whistleblowing hotline system?
“Whistleblowing hotline” is actually a misleading term, as mentioned earlier. It suggests a channel, like a simple phone line, for people to blow the whistle about a concern. However, the world of whistleblowing has professionalised since the early 2000s, as companies learn that opening up to whistleblowing is also a commitment to employees and stakeholders that cases will be managed appropriately. This requires more than a channel through which people are encouraged to blow the whistle, be that by phone or online. More often than not, the traditional whistleblowing hotline today is just one component of a broader system. As providers of a whistleblowing hotline service, this is certainly how we encourage our customers to approach corporate whistleblowing. So what does this broader whistleblowing hotline system contain?
- Communication about the whistleblowing hotline system
Communication to those groups of people to whom the organisation is making the whistleblowing hotline service available is essential. It can include ‘how to’ guidelines, a whistleblowing policy, re-emphasis of the organisation’s Code of Conduct and more. The aim of such communication is to set the whistleblowing hotline service in the context of the organisation’s broader ethics and anti-corruption work, to create trust, and thereby encourage people to use the whistleblowing hotline if they suspect improper behaviour. Whistleblowing hotline service communication will:
- Answer the what, where, when why and how of the whistleblowing hotline service? What is a whistleblowing matter, what is not? Where can people find the channel to report? When is the whistleblowing service available? Why should people bother, why can they trust the whistleblowing hotline service? How can they blow the whistle?
- Describe the case management process. What happens to complaints, how will they be followed up, escalated and investigated?
- Detail who will manage the report. Who are the members of the whistleblowing team, and why?
- Explain that the whistleblower can report anonymously, and remain anonymous throughout any follow-up dialogue and process if they so choose. Also explain that if they are comfortable with open whistleblowing, revealing their identity, they will be protected from any retaliation. Potential whistleblowers should also be informed about their rights, the rights of the accused, how data is handled and how the whistleblowing hotline software keeps the data is secure.
- The whistleblowing hotline itself
This is the channel for reporting complaints, and it must be an easy-to-use whistleblowing hotline to remove all barriers to a potential report being made. A serious whistleblower probably blows the whistle only once, and they can have great concerns about doing so. Help them by making the process as simple, and the channel as accessible as possible, and allowing them to start a dialogue as an anonymous whistleblower. Allow multi-lingual reporting so that employees and other stakeholders can use their mother tongue when reporting. Ensure the whistleblowing hotline has the functionality for adding evidential material to the case.
- A whistleblowing hotline
When a report comes through the whistleblowing hotline, this is the group of people appointed to receive and manage whistleblowing cases. They will decide whether cases should be escalated, to whom, and whether external experts need to be added into the investigation process. They will have relevant competences from multiple functions across the organisation, and training to handle ethically sensitive issues. At our customers, we often see roles from HR, Compliance, Finance and Sustainability, as well as non-executive members from the Board. This whistleblowing hotline team should be as small as possible, but contain more than one person for reliability and impartiality reasons.
- A whistleblowing case management tool.
This is the place within the whistleblowing hotline system where cases are processed. It should seamlessly integrate with the system for efficient follow-up and on-going dialogue with a whistleblower. To help the whistleblowing team manage and investigate cases correctly, it should be intuitive, and provide a structure for the most appropriate steps to be taken throughout the process. To be fully compliant with applicable legal requirements, such as the GDPR, the whistleblowing hotline case management tool should include case archiving and deleting functionality.
- Whistleblowing hotline software
Underpinning and enabling the entire whistleblowing hotline system is a robust whistleblowing hotline software solution. Market-leading whistleblowing hotline providers today ensure that their solutions contain the strictest security settings to ensure data privacy and security, in compliance with all regulations (see below). At the same time, the solution should enable you to control your own data and allow you to monitor that your whistleblowing hotline system is not accessible to any unauthorised persons.
The four characteristics of successful whistleblowing hotlines
Irrespective of format, all whistleblowing hotlines should embrace a number of characteristics that will increase their chances of success. What do we mean by success? That people trust the whistleblowing hotline service, and therefore use it. That whistleblowers are treated respectfully. That cases are managed professionally, correctly, sensitively and effectively. That the system acts preventively and thus reduces the risk of improper conduct occurring. These four critical success factors may repeat some of the points made above somewhat, but they are so important in the success of whistleblowing hotlines that we think they are worth repeating.
- Secure and anonymous
Whistleblowing hotline systems contain very sensitive, personal and potentially criminal data. Everywhere in the world, this type of data is very strictly regulated (see next point), so keeping the data safe and identities untraceable has to be a priority consideration for any whistleblowing hotline system. Security needs to permeate the platform it runs on, data storage solutions, software applications, access rights, archiving and deleting and more. Ensure your whistleblowing hotline provider has the highest security certifications and functionality across the system, that they regularly stress-check the system for security vulnerabilities, and that they follow security development closely and continuously, and keep your whistleblowing hotline software up-to-date.
- Legally compliant
Data protection laws have very real implications for whistleblowing hotline systems as they regulate how criminal and personal data is to be handled. However, data protection and whistleblower protection regulations differ and shift from country to country, making compliance monitoring complex. When selecting a whistleblowing hotline service, ensure that it has regulatory compliance already embedded into the system to help you keep abreast of changing laws. As an investigative team, you want to be confident that your whistleblowing hotline service helps you process and investigate cases without breaking the law.
If a whistleblower is considering using a whistleblowing hotline, he or she generally wants to act in the best interests of the organisation. They observe suspected misconduct and they want to do something about it, but they may not want to be involved in whatever happens thereafter. Often a whistleblower is a person who is very close to where the improper behaviour is happening, so taking that step to blow the whistle is fraught with worry, as mentioned above. This is why we insist that your whistleblowing hotline needs to make taking the step as simple as possible, otherwise you will not receive the much-needed tips that enable you to act early. One way to do this is to ensure that the whistleblowing hotline is device neutral, i.e. that people can use a mobile phone or other device to make a report, removing the need to find a private space in the workplace. And while the whistleblowing hotline interface should be intuitive, users should also receive training that is linked to your Code of Conduct.
- An integrated part of the business ethics work
Whistleblowing hotlines work best when positioned within the organisation’s ethics work. While a hotline is not the sole weapon in an organisation’s anti-corruption, anti-fraud or anti-discrimination fight, there’s no doubt that it is an effective preventive tool and an integral, reinforcing part in any organisation’s efforts to become an ethical and transparent brand. It shows an organisation’s stakeholders that it is serious about both enforcing and following-up on its Code of Conduct and promoting a culture of compliance and the highest business ethics. It also gives employees the opportunity to do their part and be accountable by reporting in good faith anything they suspect through a trusted whistleblowing hotline.
Which whistleblowing hotline service is right for you?
So you now understand that there are different types of whistleblowing hotlines and that a hotline should be more than a one-way channel for a person to blow the whistle on suspected improper conduct. It should be part of a whistleblowing hotline system. You understand the characteristics for successful whistleblowing. But how do you get started with selecting the right whistleblowing hotline service for you? There are a couple of further questions to ask that will guide your selection. To whom do you want to make a whistleblowing service available, employees, customers, suppliers, others? How quickly do you want to be up and running? Is your organisation likely to change in the coming years? In which case, you need a scalable, flexible whistleblowing hotline service. Our final tip! Why not check out a digital system more closely before you choose? You can go to our website, where we offer you a free trial of part of our WhistleB whistleblowing hotline and service. For more information about our services, contact…..