Mia Reini and Monica Lopez Reinmiller on a Risk-Based Approach to Managing Employee Hotlines

Society of Corporate Compliance and Ethics (SCCE)
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The calls keep coming in to the helpline, which is great, unless you miss that all important, high risk one amidst all the minor issues. How do you avoid that problem? In this podcast, Mia Reini, Senior Manager-Corporate Compliance and Enterprise Risk Management at The Home Depot and Monica Lopez Reinmiller, Managing Corporate Counsel-Legal Affairs, Compliance at T-Mobile provide some intriguing answers.

Mia reveals that Home Depot has made a bot a part of its compliance team. Working with IT they See more +

The calls keep coming in to the helpline, which is great, unless you miss that all important, high risk one amidst all the minor issues. How do you avoid that problem? In this podcast, Mia Reini, Senior Manager-Corporate Compliance and Enterprise Risk Management at The Home Depot and Monica Lopez Reinmiller, Managing Corporate Counsel-Legal Affairs, Compliance at T-Mobile provide some intriguing answers.

Mia reveals that Home Depot has made a bot a part of its compliance team. Working with IT they developed software which scans helpline calls in real time, looking for buzzwords that correlate with high-risk incidents. If it finds them, they go straight to corporate compliance for review.

Launched in December 2020, the bot averages several cases a day by looking for terms such as SOX, FCPA, DOT, EPA and hazmat.

For the compliance team it’s proven invaluable since it is always at work, including on nights and weekends. But, they warn, vigilance is still required. Like all software, sometimes the bot goes down.

Of course, not every organization can have a bot, and for those, Mia and Monica advocate a risk-based approach. That includes watching out for terms that a bot might, but also having someone with the requisite skills to triage the calls and flag those needing an escalated response to the board or requiring an attorney to oversee the investigation.

Both Mia and Monica also argue for a root cause analysis as part of the investigation. The US Department of Justice has been encouraging them, but that’s not the only reason they are valuable. They can help in fostering a programmatic, preventative approach to compliance that is more disciplined.

And speaking of discipline, pushing for organizational justice, they explain, is key.

It is all a part of an active approach to managing employee helplines that helps foster a healthy compliance program. See less -

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