Speak up / Whistleblowing is good for business
Regulators expect it
Best companies do it
Investors look for it
Both public and private entities should implement internal channels for whistleblower reports (with particular attention to the financial sector) with headcount 50+ employees.
- different types of channels to be available (hotline, online form, personal meeting)
- strict confidentiality
- obligatory follow-ups on cases with a final term (not longer than three months)
- information about whistleblower hotlines should be easily accessible
EU Whistleblowing Directive, 2019
DIRECTIVE (EU) 2019/1937 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 23 October 2019 on the protection of persons who report breaches of Union law
DIRECTIVE (EU) 2019/1937 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 23 October 2019 on the protection of persons who report breaches of Union law
"Each organization that sets up a whistleblowing system should have a Whistleblowing Management Function, a specific role, even if it’s not a dedicated position, with responsibilities for the administration of the whistleblowing system"
ISO 37001 Anti-bribery management systems - Requirements
ISO 37002 Whistleblowing management systems - Guidelines
ISO 37002 Whistleblowing management systems - Guidelines
«Does the company have an anonymous
reporting mechanism and, if not, why not? How is the reporting mechanism
publicised to the company’s employees and other third parties? Has it been used?
Does the company take measures to test whether employees are aware of the hotline
and feel comfortable using it? How has the company assessed the seriousness of allegations it received? Has the compliance function had full access to reporting and
investigative information? Outsourced hotlines are more effective comparing to in-house»
reporting mechanism and, if not, why not? How is the reporting mechanism
publicised to the company’s employees and other third parties? Has it been used?
Does the company take measures to test whether employees are aware of the hotline
and feel comfortable using it? How has the company assessed the seriousness of allegations it received? Has the compliance function had full access to reporting and
investigative information? Outsourced hotlines are more effective comparing to in-house»
U.S. Department of Justice Criminal Divison, Evaluation of Corporate Compliance Programs, 2020
An effective compliance program should
include a mechanism for an organization’s
employees and others to report suspected or actual misconduct or violations of the company’s policies on a confidential basis and without fear of retaliation
Companies should have in place an efficient, reliable, and properly funded process for investigating the allegation and documenting the company’s response, including any disciplinary or remediation measures taken.
include a mechanism for an organization’s
employees and others to report suspected or actual misconduct or violations of the company’s policies on a confidential basis and without fear of retaliation
Companies should have in place an efficient, reliable, and properly funded process for investigating the allegation and documenting the company’s response, including any disciplinary or remediation measures taken.
A Resource Guide to the U.S. Foreign Corrupt Practices Act. Second Edition, 2020
"...internal and where possible confidential reporting ... to report breaches of the law or professional standards or ethics occurring within the company, in good faith and on reasonable grounds"
Good Practice Guidance on Internal Controls, Ethics, and Compliance, 2010
mentioned in
APEC Anti-Corruption Code of Conduct for Business;
ICC Rules on Combating Corruption;
OECD Good Practice Guidance on Internal Controls, Ethics and Compliance;
World Bank Group Integrity Compliance Guidelines.
APEC Anti-Corruption Code of Conduct for Business;
ICC Rules on Combating Corruption;
OECD Good Practice Guidance on Internal Controls, Ethics and Compliance;
World Bank Group Integrity Compliance Guidelines.
Anti-Corruption Ethics and Compliance Handbook for business, OECD
"91% of honorees provide third parties access to their hotlines and reporting mechanisms."
"An increasing number of World’s Most Ethical Companies honorees are sharing reporting and investigations with their employees (from 14% in 2016 to 53% in 2020), the public at large (from 11% in 2016 to 30% in 2020)".
"An increasing number of World’s Most Ethical Companies honorees are sharing reporting and investigations with their employees (from 14% in 2016 to 53% in 2020), the public at large (from 11% in 2016 to 30% in 2020)".
World's Most Ethical Companies, 2020
"100% of survey respondents say that their company provides a formal process for employees to raise ethical concerns or ask questions confidentially"
IBE Report on corporate ethics policies and programmes, 2021
97% of respondents employ a speakup (whistleblowing) hotline as an integral part of the compliance program.
IBE Report on corporate ethics policies and programmes, 2020
"Companies that more actively use their internal reporting systems can identify and address problems internally before litigation becomes likely."
"High usage is more often a sign of a healthy culture of open communication between employees and management than a harbinger of real trouble."
"Managers should view hotlines as a critical component of traditional audit mechanisms and board of director meetings."
"High usage is more often a sign of a healthy culture of open communication between employees and management than a harbinger of real trouble."
"Managers should view hotlines as a critical component of traditional audit mechanisms and board of director meetings."
Harvard Business Review Research, 2018
"Whistleblowers are crucial to keeping firms healthy."
"Internal whistleblowing systems are a tool to see what you otherwise wouldn’t."
"Second hand reports are more credible and more valuable, on average, than firsthand reports."
"Internal whistleblowing systems are a tool to see what you otherwise wouldn’t."
"Second hand reports are more credible and more valuable, on average, than firsthand reports."
Harvard Business Review Research, 2020
Whistleblowing is listed within the most effective tools to detect fraud.
"Creating an effective whistleblowing
program—one that preserves confidentiality (if not anonymity), investigates cases in a timely manner and resolves them in a consistent way—is a challenge."
"Creating an effective whistleblowing
program—one that preserves confidentiality (if not anonymity), investigates cases in a timely manner and resolves them in a consistent way—is a challenge."
Kroll Global Fraud and Risk Report 2019/20
"Since 2010, the use of hotlines or reporting mechanisms has increased notably, to 49%"
"Organizations with hotlines detected fraud by tip more often, 49% vs 31%"
"Organizations with hotlines detect frauds more quickly than those without hotlines"
"Median losses were nearly doubled at organisations without hotlines"
"Organizations with hotlines detected fraud by tip more often, 49% vs 31%"
"Organizations with hotlines detect frauds more quickly than those without hotlines"
"Median losses were nearly doubled at organisations without hotlines"
ACFE Report to the Nations on Occupational Fraud and Abuse, 2020
"Software that protects the confidentiality of whistleblowers and their identity may reduce the risk of retaliation"
"Activities undertaken to ensure the proper functioning of disclosure channels may, thus, lead to fewer cases of retaliation and lower judicial costs."
"The proper setup and maintenance of internal channels may, thus, influence the probability of reporting and also of the proper handling of a disclosure."
"Activities undertaken to ensure the proper functioning of disclosure channels may, thus, lead to fewer cases of retaliation and lower judicial costs."
"The proper setup and maintenance of internal channels may, thus, influence the probability of reporting and also of the proper handling of a disclosure."
Estimating the Economic Benefits of Whistleblower Protection in Public Procurement, 2017
"... the response should never be ignorance. And it is crucial to provide a confidential means for reporting, and for having expertise and resources to look into the reports. The organizational culture is created by the daily actions by what is said and done, but also by leaving things unsaid or undone."
"Confidential whistleblowing channels... is not only about collecting reports but also ensuring that there is sufficient competence and adequate processes to assess and manage the concerns as well."
"Confidential whistleblowing channels... is not only about collecting reports but also ensuring that there is sufficient competence and adequate processes to assess and manage the concerns as well."
Nordic business ethics survey, 2019
"At a minimum, leaders need to talk consistently about ethical conduct and the ways in which the company expects their employees to behave. But just talking about ethics is not enough. Leaders must also encourage employees to speak up when standards are not being observed. Instead of relying on one-way exchanges, the goal should be a climate where employees feel empowered to raise concerns."
Building companies where values and ethical conduct matter, 2018
«One of the most convenient communication channels for employees and most suitable anonymous channel for non-employees"»
KPMG Integrity Survey, 2013
«Outsourced hotlines are more effective comparing to in-house»
IBE Effectiveness of hotlines Report, 2012
The Board should ensure that workforce policies and practices are consistent with the company's values and support its long-term sustainable success. The workforce should be able to raise any matters of concern.
The UK Corporate Governance Code, 2018
Capture and address ESG concerns by whistleblowing about climate change with a Net Zero clause in your policy
The Chancery Lane Project, Net Zero Within Company Whistleblowing Policies, 2021
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