Ethics Hotline Best Practices

In its fourth global economic crime survey, Pricewaterhouse Coopers Southern Africa (PwC) reported the following – Whistle Blowing Programmes – Best Practice Tips:

• “Safeguard employees who report misconduct against any form of retaliation
• (i.e. threats, harassment and demotion) – allow for anonymous reporting.
• Make certain employees report incidents outside their chain of command – avoiding their supervisor/department head/division leader, by using a helpline, e-mail or mail box.
• Maintain confidentiality to the fullest extent possible.
• Ensure that any hotline/helpline is both toll-free and includes as many language translations as appropriate, for a company with global operations.
• Establish working relationships and protocols for various departments within the organisation, prior to issues surfacing. For example, Human Resources or Benefits to address personnel issues and Security or Risk Management for more serious issues such as suspected fraud.

• Include controls for targeting certain situations that may require immediate steps to prevent further risk or damage.
• Provide clear governance expectations about how matters will be reported to the ultimate governing authority, presumably the Board of Directors, or sub-committee.
• Formalise processes for recording and tracking reported issues and incidents.
• Communicate information about the reporting and investigation process, how it operates, what kinds of issues have arisen and how they were dealt with.
• Establish communication channels not only for reporting misconduct, but also for asking questions and receiving guidance.
• Track trends that may appear in one business or across businesses, or specific levels within the organisation.
• Assign appropriate people with both the requisite authority and experience to perform the investigation.
• Establish a company code of conduct that requires all leadership, senior management and employees to fully cooperate in any investigation into allegation of misconduct.
• Establish and consistently enforce a disciplinary policy. A program that doesn’t abide by its own rules, from the top down, will never work effectively.
• Train and periodically update all company employees about the Whistle Blowing program, disciplinary policy and the company code of conduct.”

For more information, contact Whistle Blowing.