PLANNING AND IMPLEMENTING A WHISTLEBLOWING HOTLINE
The scope of a whistleblowing hotline will depend on the size of the business, the nature of your operations, the company’s risk profile and its global reach.
Objectives and remit
Your organisation will need to be clear about what role the whistleblowing hotline is intended to play, and what types of reports can be made through the whistleblowing hotline. This may be defined by laws or regulations applicable to your organisation. Along with other important details, this information should be included in your whistleblowing policy.
Some organisations have a whole department responsible for internal audit, compliance and ethics-related activity. Others may simply have only an ethics champion or it may fall under the remit of human resources.
You will therefore need to establish who will be responsible for the oversight and management of your whistleblowing hotline process and how it will fit with existing policies and procedures.
With multiple stakeholders involved, you must ensure all parties are engaged and understand the importance of their contribution to the success of the hotline.
Are there any trade unions or works councils you need to engage with? In some countries this is a legal requirement while in others it’s good practice to explain the purpose of the service and how it benefits everyone.
Geographic and language considerations
If you have employees or suppliers based overseas, you will need to consider how they will access and use your hotline. Think about what languages it will need to support, if interpreters and translation services are required, and if availability to the hotline is needed across different time zones.
You’ll need to take account of international laws surrounding whistleblowing, data protection and privacy, which can vary from country to country and are subject to change. Cultural differences and sensitivities that may affect the understanding, undertaking or acceptance of the service must also be considered.
A decision will need to be made about whether the whistleblowing hotline should be rolled out centrally or governed by individual countries or sites. Whatever you decide, responsibilities and roles need to be assigned and clearly communicated.
Overcoming barriers to reporting
It will be important to think about other factors that may deter staff from raising concerns – and look at ways in which they could be overcome.
You should also be aware that many staff will be reluctant to make reports if they feel they will be at risk of exposure and retaliation.
These may include a lack of knowledge about what constitutes a ‘valid’ report, or how reports should be raised – both of which should be addressed by a comprehensive communication campaign (see ‘Why Don’t Employees Speak Up’ for more advice on doing this).
Make sure your hotline is secure and all reports are kept confidential. Provide anonymous reporting options and have clear processes in place to foster trust among employees and to protect them against any form of retaliation when they make a report.
Accessibility will be important too, so Freephone or toll-free numbers and web reporting options should be made available as part of the service. A decision will also need to be made about whether the hotline service should be extended to suppliers, clients and third parties.