At Wellfleet Strategies, we believe that you shouldn’t fear whistleblowers – in fact, you should encourage your people to come forward when they believe something is wrong. We help our clients build effective whistleblower programs that give your people an avenue for raising concerns and a protocol for proceeding when something has gone wrong.
Opening the Lines of Communication
To avoid an unnecessary crisis, creating an environment where employees feel comfortable reporting wrongdoing is essential. One major step you can take is to create an internal compliance program that allows employees to report fraudulent or other illegal activities.
One potential component of such a program would be to set up an independent whistleblower hotline (phone or email) that would allow employees to report wrongdoing anonymously. You should acknowledge receipt of the complaint and inform them that it will be investigated. From there, you should keep the employee apprised of the status of your investigation and any actions that will be taken. Your compliance program should include a commitment to confidentiality and an anti-retaliation statement.
Ultimately, the goal is to identify wrongdoing and correct it before it gets out of control. In this sense, potential whistleblowers can act as an additional means of protecting against fraud and other illegal activities in your own organization.
Managing Whistleblower Complaints
Another benefit of creating a whistleblower program is that it allows you to decide how these complaints will be managed. Rather than reacting in the heat of the moment, your program will lay out how they will be handled in an orderly fashion. It will explain who will be responsible for investigating the complaint, the steps that will be taken, who will provide oversight, and checks and balances to ensure that the complaint is thoroughly investigated.
How Do You Respond?
Another benefit of an internal whistleblowing program is that it gives you the opportunity to determine how to manage the problem before facing an enforcement action from government authorities. If you determine after investigation that the complaint is valid, you need to decide the following:
- Do you self-report the compliance issue to the relevant authorities?
- What corrective action do you need to take to prevent future wrongdoing?
- What action do you need to take against the wrongdoers?
Every situation is different, and so it’s hard to incorporate the answers to these questions into a policy. Instead, you need an independent partner who understands your options and can provide valuable guidance as to the best course of action.