Making whistleblowing work

Whistleblowing. Speak-up. Ethics concerns. Whatever you call it, creating a culture that invites employees and other stakeholders to feel comfortable raising concerns about misconduct and inappropriate behaviour is one of the most effective ways for companies to identify risks and put them right before they result in a crisis.

Here are six tips to make your speak up programme work better for the company and your employees:

1. Design your speak up policy before selecting an external whistleblowing software platform. You may want a platform that allows employees to ask questions about misconduct. This can help flush out risk areas not clearly covered in the Code of Conduct. Or you may need a sophisticated case management system to support your ESG reporting requirements. Decide on your requirements first – then select a platform to help you deliver.

2. Tone from the top is essential. Confidence will make or break a speak-up programme in an organisation. Send a clear message from senior management. Videos featuring senior executives could be used to promote the programme. Or consider adding a CEO message to the introduction of the Code of Conduct to let employees hear directly from the executive team that they are doing the right thing by speaking up, and will be both protected and supported.

3. Training, training, and more training. Training investigators to look after the interests of those who raise concerns and those about whom concerns are raised is not just important, in some countries, it’s a legal requirement. In addition, training line managers to know what to do if they receive a speak up disclosure and how to deal with employees who find themselves the subject of an investigation can have a significant impact on overall staff morale and wellbeing. A bad experience with speaking up can discouraged employees (and managers) from utilising the speak-up process for future concerns – sending them straight to the regulators next time!

4. Communicate about the speak-up system regularly. Communicating and promoting speak-up systems requires constant work and commitment. Companies that do it well, work hard to reinforce speak-up messages. There are many platforms that can be used, the company website, the intranet, in poster campaigns, or through webinars and tie-ins with other internal campaigns such as on bullying and harassment or “Ethics Day” events. This can be particularly challenging in the current Covid environment where face to face contact remains limited. However, it’s even more important in this environment when companies have less oversight of what employees are doing and consequently, more risk that misconduct can slip through the cracks.

5. Implement a case management system (CMS). A CMS that tracks data from all internal reporting mechanisms (health and safety, whistleblowing, human resources, etc.) can be a game changer for its ability to help identify “hot spots” in the business in real time. It is also a highly-rated component of risk management/compliance programmes from the perspective of regulators. Whistleblowing platforms are becoming more sophisticated with these tools and they can also be useful for collating data for a company’s non-financial reporting requirements.

6. Stay on top of your data protection requirements. Whistleblowing and speak-up can be a minefield for data privacy, particularly as the rules can vary across countries. Have clear policies in place for data collected, processed and retained as part of the speak-up programme. Look for ways to use anonymised data to support your longer term risk management objectives without breaching data protection rules.

GoodCorporation offers a range of services to help companies embed successful whistleblowing systems. For more information see our Whistleblowing page.