Ethics Hotline Tip Investigations
When a company puts an ethics hotline system into place and receives its first tip for investigation, the effectiveness of the process will be determined by the investigation’s completeness and quality.
The first question will be related to the details of the anonymous tip. Does it contain sufficient information from which to launch a specific investigation or is it a broad statement with general information? When there is a lack of specificity to a tip, the responsible investigator must resist the urge to dismiss the tip as non-probative. If it doesn’t contain enough information and a hotline tool such as Ethical Advocate’s is being used, the investigator can ask the source for further information, as anonymous back and forth communication is possible.
Another way to construct an investigation plan for a vague or limited anonymous tip is to think in terms of “self-audit”. For example, if the tip is that there is an accounting overstatement being made in government contracts and if the company has numerous, current contracts plus a 10-year history of similar contracts, where does the investigation begin? Now, take that same question and reframe it as “what steps would we follow to conduct a self-audit into the accuracy of pricing for government contracts?”
We know that certain steps of investigations, self-audits, and external audits are identical: interview, evidence, analysis, documentation, and review of findings. Chances are that if you place the standard operating procedures side-by-side for an investigation of an anonymous tip and the conduct for the self-audit, you will notice similar processes. The investigation may be on a series of short deadlines and to more company officials, but the self-audit may contain specified steps to a thorough review of an entire process or department.
The contrasting issue is the anonymous tip may be so specific that you may believe you can identify the source. An immediate caution must be urged to avoid going straight to that possible source. For one, the source is a protected individual against whom you should not create any fear that confidentiality has been breached or that reprisal is imminent.
The more important consideration in the instance of a specific tip is to adhere to the pre-set investigation protocol. If the standard operating procedure for an anonymous tip has been well designed, following those steps will ensure both a thorough investigation, as well as protection of the source employee. The primary purpose of the investigation, after all, is to determine the possibility of fraud, theft, or other internal problem.
As you undertake your investigations based upon anonymous tips, you can count on Ethical Advocate as your trusted partner. From tips and data collection through confidential pathways to analysis of tips and data, Ethical Advocate will add the necessary expertise to help your company focus upon the compliance issues that impact the bottom line. Whether your investigation is in finance, human resources, or some other critical area, contact us if you need additional assistance.