Never Underestimate – Your Company’s Hotline(s)

The Volkov Law Group
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Every company has put in place a reporting hotline – whether a telephone number and/or website, companies offer employees an avenue to raise a concern. Employees will report concerns, but they have to trust the reporting system to be responsive.

When you ask compliance professionals and others who monitor the reporting system if it is valuable, you hear the common statistic – 80 percent of the reports are trivial employee relations matters – my boss was mean to me; my co-worker insulted me, and on and on.

A dismissive attitude towards a company hotline reflects a dismissive culture. The value of a hotline is not the number of the complaints and the types of complaints. Instead, a carefully managed and operated hotline can promote the company’s responsiveness and interest in hearing employee concerns.

When a CEO stands in front of a group of employees and urges employees to report concerns – the number of reports will increase dramatically after the CEO’s statement. That is a given.

When a company reiterates its interest and support of the hotline, employees will use the hotline to communicate their concerns. Most employees, however, want to report concerns to their immediate supervisor. That is just human nature.

A robust reporting system that is promoted and highlighted as an important component of the company’s management system can be an invaluable resource to a company, senior management and the compliance function.

Additionally, a robust hotline reporting system can bring in and uncover major issues – The Goodyear FCPA enforcement action from last year began from an employee concern raised on a hotline. For Goodyear, if unreported, the FCPA problem could easily have become bigger and more dangerous to the company. The one in one hundred call that comes in may reveal an important compliance concern that needs to be addressed.

Company hotlines create a real opportunity for promoting a culture of compliance. If a company regularly attends to the calls, monitors the nature of the calls and analyzes the data, the company can develop real insights and patterns and practices within the company.

If, for example, employees are raising similar concerns about a supervisor in a particular office, the company can respond and proactively address the issue before it becomes more significant. The numbers of complaints are not relevant so much as the types and locations of complaints that are collected on a hotline.

Company reporting systems should not be limited to just a call in number. Promoting multiple avenues for reporting employee concerns might be cumbersome but can lead to increased communications of concerns. There is no magic bullet for what reporting system to establish, nor is there a magic number or type of reporting system.

Employees should be given the opportunity to report a concern anonymously. While it may make it difficult to follow up on a concern with teat employee, there are ways to respond to the anonymous complaint and request additional information. Some employees value anonymity as a means to protect themselves from retaliation – a real and growing threat to employee concerns.

Finally, a company can demonstrate its commitment to its culture by ensuring prompt and effective responses to employee concerns. If the system is proven to be effective and companies respond and resolve matters quickly, more employees will participate and pick up the phone and report a concern. A company’s trust factor increases with responsiveness and reliability.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© The Volkov Law Group | Attorney Advertising

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