Companies spend a lot of time and effort promoting a “Speak Up” culture. Even before the SEC’s whistleblower program, senior managers recognized that they needed to know what is occurring in the company. The only way to learn is to encourage officers, managers and employees to speak up.
It is easy to say you are committed to such a culture. It is much harder to put in place the resources and capabilities to ensure such a culture. Companies have to develop a structure and set of practices that are designed to escalate important issues within the company.
Of course, companies maintain and promote a hotline service. Remember that, when surveyed, employees by an overwhelming majority want to report their concerns to their immediate supervisor. That is where the major disconnect occurs – when surveyed, direct supervisors report by over a majority that they feel unprepared to deal with employee concerns. That is the essential disconnect that every company has to address.
Here are four important steps to promote your company’s speak up culture:
Train Managers: A Chief Compliance Officer has to target managers for specific training on how to respond to employee concerns. Managers want to know what to do with employee concerns. They want their employees to have a positive morale and they need to know what to do when faced with a specific employee concern.
In many cases, the manger will end up serving as a “traffic cop,” meaning that the manager will coordinate with other offices, such as Human Resources, Legal or Compliance to address the employee concerns. As a coordinator, the manager will become a problem solver and more employees will feel comfortable brining their concerns to the manager.
Tools and Resources: Managers need access to tools and resources to handle employee concerns and to discuss the complaint and internal investigations process. In order to be advocates for the internal justice system, managers need tools and resources to respond to employee concerns. They need materials that outline the internal allegation process and they have to be able to explain the process to their employees.
Communications Cadence: Managers need to adopt and implement a regular communications cadence among their employees on the importance of speaking up and raising concerns. If the manager has a monthly meeting with employees, the manager has to make sure that he or she dedicates sufficient time to the issue, reporting on employee concerns (to the extent they can be) and encouraging employees to raise such concerns.
Annual Evaluations: A company should incorporate specific expectations on manager and employee behaviors into their annual evaluation process. A manager should be evaluated on his or her commitment to encourage employees to raise concerns and to handling such concerns in an appropriate manner.
In the end, a Speak Up culture depends on the interaction of managers and employees. A CCO has to recognize this basic fact and cultivate this relationship by creating a process to make sure that all managers can carry out their responsibilities in this area.