Yes, it’s time to give your ethics hotline an annual checkup. Start with the most basic question of all. Does your organization provide an ethics hotline for all employees and other stakeholders? If the answer is no, you might want to review some top reasons for implementing ethics hotlines. If the answer is yes, continue with the checkup.
You’ll want to confirm that the features of your ethics hotline still compare well to best practices and your industry’s standards.
The following list was taken in large part from consulting firm Deloitte’s 2015 list of “common features of complaint helpline/hotline systems” found in its 2015 Audit Committee Resource Guide, with additional suggestions from Harper and Ingram’s 2016 “Addressing Compliance & Ethics Risks in the Newly-Acquired Entity” (which includes advice on what to check for in general compliance and ethics programs). Such systems are:
- operated by an independent third party;
- staffed by trained interviewers rather than fully automated systems;
- accessible via a dedicated phone number that is available at all times, along with other reporting means such as fax, website, email, and regular mail;
- accessible in all countries (and locations) where the company has employees;
- multilingual—both systems and operators;
- available in all languages spoken by the company’s employees; and
- well publicized.
Such systems also:
- allow complainants to call back and give them the option to file complaints anonymously;
- protect complainants from any retaliation related to reporting;
- have protocols in place to allow complaints to be channeled to the appropriate individual, with complaints involving senior management going directly to the audit committee;
- handle complaints in a confidential manner and resolve them as quickly as possible; and
- ensure complaint procedures are well known to all employees, vendors, and other interested parties.
Your hotline program was undoubtedly set up to achieve most of the preceding features and protections. Part of the annual checkup is to ensure the program is still functioning the way it was designed to.
Therefore, you’ll want to review your hotline policies and operating procedures. As you engage in reviews of your hotline’s features and processes, you may uncover hints that day-to-day practices have deviated somewhat from policy. Take the time to formally assess how or if hotline-related practices have changed (or should have changed) and if those changes are for the better. Are the policies and operating procedures still valid? Are they being followed consistently, across the organization? What has changed, where, and why? As needed, undertake the careful process of updating the policies and operating procedures and reintroduce them throughout the organization. Or, develop and implement communications and training efforts to bring practice back in line with policy.
Conducting a thorough review of hotline features, policies, procedures, and day-to-day practices is no small task, especially in a large multi-facility organization, but it needs to be done. It might not be possible or necessary to assess every aspect of the hotline program every year but it should be possible to review the entire program every two or three years by systematically scheduling an annual checkup for different parts of the program each year. It will be worth the effort.
Ethical Advocate assists companies of all sizes in creating a culture of ethics and accountability by providing ethics and compliance training, confidential and anonymous hotlines, and assistance in meeting regulatory and reporting needs. Contact us for more information.
Deloitte LLP. Audit Committee Resource Guide, February 2015. See https://www2.deloitte.com/us/en/pages/center-for-board-effectiveness/articles/audit-committee-resource-guide.html
Harper, Daniel R. and Kasey T. Ingram. “Addressing Compliance & Ethics Risks in the Newly-Acquired Entity,” 2016. http://www.corporatecompliance.org/Portals/1/PDF/Resources/past_handouts/CEI/2016/601_ingram-harper_2.pdf