“If you see something, say something” has become a mantra for public safety, but the idea has an important role in organizational culture as well. Illegal or unethical behavior can happen even in the best organizations, in the best of circumstances. Organizations must be proactive about identifying and addressing issues before they balloon into problems with serious financial, legal or reputational impact.
Establishing a hotline (or “reporting line,” “whistleblower line” or “help line”) where employees can report illegal or unethical behavior can help organizations manage issues rather than be caught off guard. A good principle is to make hotlines as easy to use as possible: They can be set up internally or through a third party and can include options for reporting by telephone, web and even text messaging.
As valuable as these tools are, they are only effective if they are used. A “cold” hotline won’t help an organization get in front of an issue. Hotlines must be “hot” so that those who are aware of illegal or unethical conduct use them to report the problem.
Although fraud, sexual harassment, and other bad behavior can occur in the main office or at a place where there are many people who can potentially call out the behavior, some of the greatest risks are on the periphery of an organization. The edges of an organization are often the areas with the most opportunity to engage in bad behavior due to less oversight, high pressure, and easier rationalization of bad behavior. Organizations need to receive hotline reports from people on these edges, but they are often on the margin or only very loosely connected with the organization. They may be independent contractors, employees in a remote location, subgrantees, or service providers. Often, they only have limited, if any, interaction with the organization’s main office and their connection back into the organization may be just one person, with whom they may only have intermittent contact by phone or email. Organizations must ensure that these people are aware of the hotline and have access to it.
Make Sure Your Communication Rollout Reaches the Edges of Your Organization
A successful rollout of a reporting line requires a great deal of communication. Having a blurb in your internal newsletter, posting in your Slack channel or intranet, and sending a mass email are all important and effective ways publicize your hotline. Having a link or information on your website is also an excellent way to communicate about your hotline. Physical print communications are important, too. Consider posters in each office, often next to mandatory labor posters, small flyers left in common areas or on desks, and even business card sized notices about your hotline. In any communication, be sure to include the web address and phone number for the hotline as well as a short description of why and how it can be used. If you operate in various countries and cultures, have local staff review your materials and consider engaging a professional translator to make sure the communication is accessible in the languages your team members use.
Include Hotlines as Standard Material in Trainings
Training should be viewed as an opportunity to advertise your hotline. Add a slide to the end of every training conducted by your legal or compliance department (and invite other departments, such as HR, to do the same) listing the hotline number and web address and reminding staff that the hotline is there as a way to report illegal or unethical conduct. If your staff must certify attendance at a training, consider adding a question to the certification asking if the staff member knows how to report illegal or unethical conduct. For anyone that marks “no,” have a plan in place to reach out to them and provide information on the reporting avenues, including the hotline, available in your organization. In addition, be sure to include information about the hotline in your onboarding package for new employees.
Include Hotline Provisions in Your Contracts
Organizations often do a good job of reaching their employees with information about their hotline, but it’s not just employees that may have something to report. Adding a simple contract provision notifying your contract partners, from independent contractors to subgrantees, that your organization maintains a hotline and providing details on how to access it can help ensure that illegal or unethical conduct is reported. It also helps to send a subtle message to your contract partners that you take legal and ethical obligations seriously and expect them to do the same.
Ensure That People Can Report in Their Own Languages
For international organizations, having a hotline that is accessible globally is fundamental. Of course, this means having a web reporting tool and a 24/7 phone number, but it also means ensuring that people can report in their own languages. Whether managing your hotline internally or through a third party, making the hotline available in the languages most frequently spoken in your organization will help people, especially those on the periphery of the organization, feel comfortable reporting their concerns.
Rolling out a hotline is a large task, but it can be done in an iterative manner. Start with some of the ideas listed above and slowly expand the capabilities and reach of your hotline based on your capacity and the change appetite of your organization. As you roll out your hotline and reports start to come in, manage each report professionally and expeditiously. As staff members see or hear (word always gets out) that your organization is taking reports seriously, your hotline will stay hot.