Tagged: employee concerns

Monitoring and Measuring A Company’s Ethical Culture: Relevant Survey Strategies (Part I of II)

Chief compliance officers play a key role in managing a company’s ethical culture. Most companies fail to pay proper attention to its culture because it is difficult to define, measure and monitor. Such an approach is short-sighted. CCOs have to embrace this issue and develop appropriate techniques to measure a company’s culture. All too often I observe companies that rely on annual or semi-annual company-wide...

NAVEX Global’s 2019 Hotline Benchmark Report

NAVEX Global’s Hotline benchmark report (here) is an excellent annual report which helps companies to understand how well their hotline and incident management system is operating.  The survey is based on over 1 million reports from 2,738 customers.The NAVEX report also is based on all types of reporting avenues, including hotlines and web-based systems. Interestingly, NAVEX noted that overall reporting rates remained consistent with 2016...

Episode 61 — How to Implement and Promote a Speak Up Culture

Companies face a myriad of risks that can cause significant legal and reputational risks.  A company’s employees are critical sources of concerns to prevent and detect problems.  Employees have to be encouraged to raise concerns to help the company address these problems proactively.  As a result, it is critical for companies to invest and promote its speak up culture to maximize employee communication and prevent...

Time for Companies to Establish an Independent Corporate Ombudsman

Corporate commitment to speak up cultures is suffering.  The Ethics and Compliance Initiative’s recent Global National Business Ethics Survey (available HERE) contained a critical finding – corporate instances of retaliation against employee for raising concerns doubled in the last five years. In the 2013 survey, 22 percent of respondents reported instances of retaliation against employees.  This number increased to an astounding 44 percent of respondents...

ISO 37001: Training, Employee Concerns, and Internal Investigations (Part V of V)

In my final posting on ISO 37001, I review requirements for training, raising concerns and internal investigations as part of a company’s anti-bribery risk management system. I could certainly write more on ISO 37001 because there are other issues that I have not addressed, including audits, assessments and reviews of the anti-bribery risk management system. In this posting, it is important to identify and tailor...

What Happens When Employees Stop Speaking Up?

One of several difficult compliance questions facing companies revolves around reporting of employee concerns. If the number of complaints coming in on a company hotline goes down over time, is corporate misconduct going down or are employees losing trust in the company’s speak up system? These are two diametrically opposite conclusions. Compliance officers have to be realistic and objective when analyzing this question. Misconduct rates...

Knowing Your Employees and Incident Management Systems

Chief compliance officers know the importance of trust, not just as a foundation of a global company’s compliance program, but in the context of knowing what company employees are doing out in the field. CCOs will always say they have a “feel” for what is going on at the company but when they are reminded of how little visibility they have into company operations around...

Never Underestimate – Your Company’s Hotline(s)

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...

Creating an Ombudsman’s Office

If your company is big enough and has the resources to consider establishing an internal ombudsman’s function, consider yourself lucky. When compliance professionals and lawyers use the term “ombudsman,” it is important to define how the term is being used. The most effective model for an ombudsman is the creation of an entire independent investigation and resolution function within a company. In this model, the...