Today, I made my
compliance colleague from Russia happy by sending her more insights and
practices on how to take up an ethics helpline from zero.
How to start and what is good to know even before you start it...
I am glad to have an international network of compliance and ethics
professionals to be able to share knowledge and experience.
I thought this
might fall in the interest of many when facing similar challenge.
Here it is...
Dear D. E.,
...I wanted to prepare something really useful and practical for you. So, I ended up writing an entire handbook on how to establish ethics helpline :), which I can now use in my blog, too. …
...I wanted to prepare something really useful and practical for you. So, I ended up writing an entire handbook on how to establish ethics helpline :), which I can now use in my blog, too. …
Taking into account best
practices and some of my experience / lessons learned, I came up with the
following steps when implementing an ethics helpline from scratch.
Next to that, you will find
some links to the resources, where you can find examples of:
- code of conduct
- ethics helpline policy
- ethics helpline platform
- non-retaliation policy...
all of which are needed for setting an ethics helpline framework and you will probably create them tailored for your own company, if you don't have them.
- code of conduct
- ethics helpline policy
- ethics helpline platform
- non-retaliation policy...
all of which are needed for setting an ethics helpline framework and you will probably create them tailored for your own company, if you don't have them.
Resources available at SCCE
(Society of Corporate Compliance and Ethics) web-site are great and generated
at one place. ... I highly recommend you to try to attend their events, too.
They are great! You can search SCCE's web site for the events and many
resources on compliance and ethics; For this, go to: https://www.corporatecompliance.org ; Choose:
"Resources" -> "Library" or "Surveys".
THE STEPS FOR
IMPLEMENTING AN ETHICS HELPLINE - THE SMART WAY:
1. Before setting up an ethics helpline, discuss it with your management, best with the CEO, or whoever is giving you a mandate to set up an ethics helpline (or an overall compliance program / internal control system):
1. Before setting up an ethics helpline, discuss it with your management, best with the CEO, or whoever is giving you a mandate to set up an ethics helpline (or an overall compliance program / internal control system):
- make your own mandate and
responsibilities of others regarding the helpline clear,
- monitoring and reporting about the helpline statistics and effectiveness must be specifically determined,
- find out about the objectives and expectations of management about the helpline / compliance program,
- discuss what kind of misconduct do you want to be reported (only breaches of laws and regulations or internal policies included; only specific kinds of breaches – most severe or any kind ??),
- specifically discuss with legal all the necessary aspects; especially the importance of reacting upon reports and substantiated misconduct (include HR in this, too), discuss arranging the client- lawyer privilege when needed and what if a report is raised against the higher management etc.,
- discuss basic issues also with teams of line managers and your peers;
- monitoring and reporting about the helpline statistics and effectiveness must be specifically determined,
- find out about the objectives and expectations of management about the helpline / compliance program,
- discuss what kind of misconduct do you want to be reported (only breaches of laws and regulations or internal policies included; only specific kinds of breaches – most severe or any kind ??),
- specifically discuss with legal all the necessary aspects; especially the importance of reacting upon reports and substantiated misconduct (include HR in this, too), discuss arranging the client- lawyer privilege when needed and what if a report is raised against the higher management etc.,
- discuss basic issues also with teams of line managers and your peers;
- help business
people to understand the benefits; why excellent companies find this kind
of reporting from employees highly valuable for the sake of company's integrity
and reputation (first convince yourself and become immune to discouragements);
These are the most recognized benefits of an ethics helpline:
- having an internal line to report issues helps company to lowers the possibility of negative public exposures, due to lower possibilities that employees would report issues to external bodies or directly to public, given that internal reporting and resolving procedure is existent and effective; in times of social media, bad news gets out easier and spreads faster than ever, so the reputational risks are even greater,
- also, it can help clear issues at more early stage and help protect company, employees and management from harm of greater consequences latter
- supporting a speak up culture and effectively reacting against wrongdoing, you bust up the integrity, consequently a respect and loyalty from employees towards the management grows; this also shines out brightly and attracts best human potential, best customer and investors
- last, but not least: it helps protect the company and its management from legal liability, for it improves chances to demonstrate that controls and due supervision were in place.
These are the most recognized benefits of an ethics helpline:
- having an internal line to report issues helps company to lowers the possibility of negative public exposures, due to lower possibilities that employees would report issues to external bodies or directly to public, given that internal reporting and resolving procedure is existent and effective; in times of social media, bad news gets out easier and spreads faster than ever, so the reputational risks are even greater,
- also, it can help clear issues at more early stage and help protect company, employees and management from harm of greater consequences latter
- supporting a speak up culture and effectively reacting against wrongdoing, you bust up the integrity, consequently a respect and loyalty from employees towards the management grows; this also shines out brightly and attracts best human potential, best customer and investors
- last, but not least: it helps protect the company and its management from legal liability, for it improves chances to demonstrate that controls and due supervision were in place.
2. Address the existing worries and accept good
suggestions before you set up the
helpline, so you can take it into account when writing policies, procedures and
communication.
Also search for and build your support group inside the company, because for sure you will have opposition.
Also search for and build your support group inside the company, because for sure you will have opposition.
3. Prepare or re-new
the Code of conduct / Ethics Code for the basis, if you don't have it
or if it's outdated;
It's good practice to be clear in your code of conduct what kind of breaches should be reported to an ethics helpline and to prohibit retaliation against reporting employees in good faith. Also provide direct contacts to which reports can be submitted. If it's possible assure anonymity or at least confidentiality.
It's good practice to be clear in your code of conduct what kind of breaches should be reported to an ethics helpline and to prohibit retaliation against reporting employees in good faith. Also provide direct contacts to which reports can be submitted. If it's possible assure anonymity or at least confidentiality.
4. Create your own,
company-tailored ethics helpline policy and procedures, including
non-retaliation (reporting employees protection). If you don't protect
employees from possible revenge, they won't report serious issues or won't
report any issues.
The policy should define all responsibilities for receiving and managing reports and for investigating and then acting upon them.
The policy should define all responsibilities for receiving and managing reports and for investigating and then acting upon them.
5. Decide on and set
up an IT support for receiving and managing the helpline reports; it
can be as simple as a special mail-box and excel sheet, or you can have ready
to use IT tools.
6. Design a
communication plan for gradual and consist communication to employees
and managers about the helpline, the policies and procedures; always emphasize
reasons behind it, benefits, that the reporting is kept confidential and
retaliation is prohibited. Partner with your PR about this.
7. Launch and good
luck!
EXAMPLES AND RESOURCES
Code of Conduct - Sisco
Business Conduct Guidelines - Siemens
Siemens compliance system - with and ethics
helpline ("Tell us" line):
ING Bank / Group Whistelblowing policy and a
compliance platform:
An Ethics Point of Schneider Electrics, France
(with different possibilities for helpline reporting):
Aon Ethics Helpline:
HR Non- retaliation Policy - from SCCE web-site:
