Handling Hotline Data

An ethics hotline creates opportunities for companies to improve compliance, reduce fraud and theft, rapidly investigate complaints, and promptly begin remediation and reporting.

But a hotline won’t run itself.  To achieve these core goals for the anonymous hotline, a company must enact standard operating procedures that will utilize the data from the hotline in a best fit to the company structure.  When standard operating procedures are in place, both the anonymous tips and the periodic, aggregated data can become the fuel to achieve these core goals.

Part of the design for the standard operating procedures for hotline tips and data has to do with the anticipated topics of such tips and the persons or departments best suited to respond.  For example, if the company handles government contracts in military procurement and a tip comes in alleging excessive charges being made to the government for a large order of finished product, who is the most knowledgeable in the company organizational chart to receive the tip, understand its content, and begin and oversee an investigation into its truthfulness?  Or, does the company want one person to receive all tips in the form of a dedicated investigator to work with managers to conduct a standardized investigation on a company-wide basis?

In addition to response considerations, a company should also make decisions on routing of tips and data.  For certain types of tips, there may be a legal requirement for the captured data to be routed to a particular level within the company, including, but not limited to the board of directors.  The standard operating procedures should reflect any legally required parties to be routed the tip or the report, including any time limitations on transmission and any required documentation or response.

There is also the consideration for a company on making the data available to various managers and leaders within the company, particularly if the company wants to strive for best practices in all departments.  One standard operating procedure might be set up for monthly reporting with written responses to data, all emanating from a central person within the company.  A standard set of questions can be developed to drive independent reflection by managers and leadership on the hotline data.

Whether handling an individual tip or a report of aggregate data, adopting written routing procedures will maximize usefulness of information from an anonymous hotline.  And, when the standard operating procedures are a thoughtful reflection of your company’s structure and available talent, hotline tips and data can be converted into sparks for a global improvement in company function.