H is for Hot Line

Copyright © 2018 by Barney Rosenberg President, Ethics Line, LLC™ barney@ethicslinellc.com

Some people in the ethics field are very fussy about what we call our “hot lines”.  They have their reasons, I’m sure.  The range of choices is:

1. hot line;
2. call line;
3. ethics line; and
4. help line to you name it. No, really, you name it and let us all know if you are aware of others, please.

The system I am most familiar with operates like this.  These are the key things I look for in assessing how well any “hot line” works.  It may be a good checklist:

1. How do people even know about the “hot line”? The usual ways are posters in all the facilities; references in the company’s ethics policies; and reminders during training.
2. Internal Audit is tasked with making sure that the posters are placed prominently while they are on-site conducting their financial audits.
3. Employees and people outside the company are free to call. They are encouraged to raise questions or concerns.  It can simply be “I don’t understand X.  Can you help me?” or “Such and such is happening and it’s wrong/illegal.”
4. People are encouraged to call if they don’t feel comfortable speaking to someone face-to-face where they work. We can only solve problems that we know about.
5. An independent, external service provider, based in Europe, with truly global reach, handles the incoming, toll-free calls and/or the web-based service for online questions or concerns.
6. Their services are available 24/7, 365 days a year…even the extra day in February during leap years.
7. Their system can recognize the country in which the call originated and they can have a translator available, live, in a matter of a few minutes, if English is not the caller’s first language.
8. The caller has the option to remain anonymous or provide their name and contact information. If they choose to remain anonymous, an investigation may be a little harder but the operators are trained to get enough information so that the company can conduct a proper investigation.
9. Anonymous callers are given a unique case number so that they may call back for feedback.
10. They are told to call back in 4 weeks, by which time it is expected that the company will have findings and recommendations.
11. All calls are managed centrally in the company and all reports are transcribed and sent to the senior ethics officer who decides who should investigate and report out.
12. If there are concerns raised about the person who would typically investigate, the senior ethics officer may select someone from outside that business or even outside the division of the company, to assure objectivity and independence.
13. If, heaven forbid, there should be a complaint about the senior ethics officer, that officer is by-passed and the written report is sent to that person’s manager.
14. Generally, the investigation and follow up is conducted at the business location by the site’s Ethics Coordinator. In some companies they are called Ethics Ambassadors.  They are the embodiment of the company’s ethics program and are also available to help with training and to generally point people in the right ethical direction.  They have other, full time jobs at the site.
15. Confidential information, such as HR actions in response to the investigation, are not disclosed. Instead, the caller is told whether their allegations were confirmed or not; that appropriate action was taken; and that they should expect to see results at their work location.
16. They are thanked for calling and invited to call again if the circumstances don’t improve.
17. They are reminded that the company does NOT permit retaliation for calling the service.
18. The company maintains a database of all calls and can generate reports based on the nature of the complaint; the business location involved; the division to which the business reports; the number of cases open and under investigation; and the country involved. Pie charts and all!
19. On occasion, new policies are required to correct a situation that may extend beyond one location.
20. An employee engagement survey will give you some insight into how well your system is working.

Your turn.  Care to share how your company does it…if you do?  Thank you.