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CCCA_V4No3_Dept-Ethics-V2.qxd:CCCA_V1No2_Dept-CourtLeg-V1.qxd 9/2/10 7:33 AM Page 18 Ethics Filing a complaint with the organization’s that no action had been taken. hotline is generally a last resort,after man- That’s why centralizing receipt and agement has ignored earlier warnings. analysis of complaints from all sources, At this stage, for the employee to con- including those filed through a hotline, is tinue trusting his employer, there must critical. Supporting this with the creation be some evidence that the complaint is and maintenance of a data management taken seriously. system to record, track and consider com- To that end,organizations must keep the plaints, results of reviews or investigations big picture in sight at all times so that of the complaints, can go a long way to trends, patterns and trouble spots can be better understanding and effectively han- identified. I once came across a case in dling complaints. It helps investigators which a company received more than 50 detect trends, patterns and trouble spots, complaints in a three-month period about and connect the dots to see the big pic- one of its business units. Employees had ture. The data management system can openly encouraged one another to file also serve to create a risk map of troubled reports with the hotline. Complaints fell business units requiring ongoing monitor- into one of three categories: 1) financial ing or investigation. It also makes it easier irregularities and fraud,2) conflicts of inter- to record, track and act on complaints. est (including misappropriation of assets) The organization must also understand and 3) workplace harassment (including how the ethics and compliance program retaliatory employment actions). operates as a system and adhere to its own Though the company eventually under- policies and procedures. Failure to do so took an investigation, it considered each can lead to incorrect outcomes and a complaint individually and for the most breach of the system,resulting in the loss of part concluded that each one in and of integrity, which forms the very basis of a itself required no action. Employees soon compliance and ethics program. Consider, lost trust in the hotline, knowing how for example as is common,a large multina- many reports had been filed and seeing tional company that has assured employees What does it take to operate and maintain a whistleblower program that is trusted by employees and builds integrity? 1. Protect the rights of complainants to remain anonymous and file reports confidentially 2. Ensure the source is not subjected to retaliation 3. Standardize and follow procedures for handling and processing complaints 4. Set clear time limits for responding to queries and complaints and communicate them to the organization 5. Consistent follow-through on complaints and consistency in actions when resolv- ing or closing cases 6. Report back to complainants and regularly publish meaningful information on hot- line performance 7. Understand the ethics and compliance system as a whole and adhere to your own policies and procedures; and 8. Be sure to always look at the big picture when handling complaints. CCCA63_053.indd 18 09/08/2010 09:31:52 PM