Regardless of your industry, we believe if you care about your people you want to make sure they’re treated fairly and behave properly. That said, if you are more than one management layer removed from the ‘front lines’ then a secure and high quality anonymous reporting hotline is essential. A properly scoped, implemented, and managed hotline supports your knowledge about what potentially damaging behavior you can address as well as employees’ sense that they work somewhere that cares about their concerns and is willing to address them.
Clearly, this critical conduit for communication is too important to under-resource. Unfortunately, the difference between a well executed solution and an ineffective (or worse, liability-inducing) one can be deceiving. Like most elegant solutions, the ‘devil is in the details.’ If you are making just a few of the mistakes below you could be leaving your employees, your customers (students, patients, etc.), and your company open to critical damage to your public reputation and threats to safety.
- Breaks in anonymity: having obvious or assumed ways employees will be improperly identified when they want to report anonymously. In addition to compounded legal liability from potential retaliation, employee concerns about broken anonymity will lead them to not report misbehavior, and leave you in the dark.
- Poor communication: people aren’t reminded and encouraged to report with clear information. If employees are talking about a problem to their colleagues, their friends, and their lawyer before your compliance team, you won’t hear about something until it’s too late. Make sure you’re communicating about the paths and strengths of your reporting avenues frequently so the message isn’t lost amid new hire and annual compliance training.
- Inconsistent follow up: reports are not addressed as part of a consistent process monitored through to close-out. When an employee reports something and never hears back, they may assume the compliance team (and company leadership) are as apathetic about the problem as the people causing it. Ensure your team is trained, empowered, and managed to address, close out, and correct reported issues within acceptable and clearly communicated standards.
- Limited first-touch collection: your initial report is limited in scope and lacks the information a coordinator needs to act promptly on the information. If your team is slowed down because they have to redo the initial interview, and callers are frustrated they have to repeat themselves your hotline becomes a liability instead of a force for positive change. Whoever takes that first call should be trained and coached on getting the ‘standard’ or basic info plusasking intelligent follow up questions based on the incident and compliance team priorities.
- Insufficient feedback: the health of your caseload follow up is hard to assess and impact because you don’t have visibility. This leaves your team overworked, your cases piling up, and your risks hiding until they begin to smoulder. Partner with a vendor who helps you manage the whole system, and adopt a compliance case management platform that makes it easy for you to check on performance.
- Disparate investigation notes: notes and activities are all over your organization, if they’re collected at all. In addition to making complex issues that involve different departments hard to manage, a disjointed record set leads to messy audits and unverifiable resolutions (especiallywhen IT issues or employee turnover make things worse). Make sure all your hotline issues are integrated with the activities, information, authorization, and conclusions about that case whether it’s in a self-managed file/database or a professional compliance case management system.
- No audit trail: minimal information about when and how information has been collected and changed. Without an audit trail, the information you do collect is subject to tampering and difficult to rely on. Make sure your hotline reports make their way into a secure system that tracks who made what change, accessed what file at what time, etc.
- Poor service levels: long wait times and rushed calls lead to the real issues. These metrics are simply indicators of the experience callers have on your hotline. Make sure your vendor is accountable for not only the timing and performance of things reported in the phone server but also the quality of the caller experience. Test calls can be a big revealer, but ultimately the culture and heart of the team will win out over your preferences if they aren’t matched.
- Over-prioritize legal concerns: calls are handled purely as creation of legal records rather than interactions with actual people. Your team may be on a treadmill just to check a box rather than driving the quality, safety, and cultural improvement that’s possible with an effective hotline. Collaborate with legal, vendor, and internal teams to find the right balance of cold data collection and thoughtful engagement to make sure you do what you (legally) can to treat callers with dignity and understanding.
- Unclear resolution and substantiation: callers never find out what happened with the report they made. If it seems like nobody cares and the report is a waste of time, word will get around and employees will stop speaking up. Make sure you have two-way communication options, even for anonymous reporters, so you can share properly scoped information about what was done with a report.
- Limited re-communication: telling people once a year about the issues they should report and how to do it. We are inundated with data and distractions and people will report much later (or never) if you rely on their memory of a training 11 months ago. Work creatively to build engaging, relevant, and convenient reminders into your communication plan – and collaborate with other departments whenever you can!
- Lacking integration: compliance is a voice in the wilderness that gets ignored. When it’s up to you to compete for the limited attention of employees you’re bound to miss some valuable ears. Work with training teams, line managers, task forces addressing/reacting to specific problems, etc. to communicate how a well-integrated compliance hotline can support all those efforts.
- Don’t celebrate wins: compliance is the unsung hero nobody knows about. When interactions with your hotline, training, or compliance investigators is seen in a negative light people are less likely to engage and report. Find liability conscious ways to announce and celebrate positive impacts compliance has taken part of including improving culture, initiating quality and employee relations fixes, and helping employees see the far reaching impact of their decisions.
The hardest part about getting an anonymous hotline right is how deceptive your performance can be. You may get a small number of calls and think there is nothing unknown to be worried about. Or you may get a high rate of frivolous or misaddressed calls (e.g., someone asking for their paystub) and assume that if you’re hearing all these things there must not be anything more concerning going on. Unfortunately, the fact that you don’t know about a problem doesn’t keep it from harming your people. So we suggest you or someone on your team find reliable ways to make sure you’re on the right track: benchmark against industry standards, build a culture of continuous improvement, collaborate with peers in your industry to find out what works for them, and get expert advice on how to do this right. Of course, ComplianceLine is here for you with that advice, clarity on the right solution, and service to make sure you’re focused on the issues most important to your stakeholders and your goals.
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