With hindsight, it is often easy for an organisation to identify the chain of events that led to an ethical risk materializing as well as the missed opportunities where the course could have been reversed. In advance, those moments seemed less important or it was believed that there would be enough time to rectify the situation. In the absence of a clear message or information about wrongdoing, there may not be sufficient impuls to react and put things right.
In this sense, an effective whistleblowing channel and processes are like a tsunami warning system for an organisation. They help to create awareness and catch wrongdoing as early as possible.
It is therefore very much in the company's interest to have a whistleblowing channel in place. Unethical or illegal behaviour can cause considerable damage, both directly and indirectly (reputational risk). A proactive reaction prevents the situation from escalating to a larger scale. According to the 2018 ACFE (Association of Certified Fraud Examiners) Global study on occupational fraud and abuse report, the most common way to detect misconduct or other wrongdoing (40%) is to receive a report about it.
The whistleblower usually hesitates for a long time before reporting. They are afraid of what kind of consequences the reporting can cause. Often the whistleblower also questions his/her own findings: "I wonder if I really saw what I think I saw." It is important to strengthen the culture of speaking up. It is also particularly important to ensure that all communication about the channel - including the choice of words - is neutral and not, for example, talking about a snitching channel.
It is good to recognise that the professionalism of the process and the case managers is also strongly part of the message when talking about the importance and the role of the channel. A trustworthy channel and handling process supports and encourages the whistleblower. Sensitivity and acknowledgement of the reported incident are part of the competence.
If a report is initially interpreted as appropriate, an investigation will be launched and the potential inappropriateness of the report will become apparent as the investigation progresses. If, on the other hand, the report is first interpreted as inappropriate, the investigation will not be launched and therefore the initial misinterpretation will not become corrected by further examination. For this reason, management should encourage case managers to ensure that reports are always treated with care, even if they would not at first sight appear to be justified.
The earlier a misconduct, damage or inconsiderate behaviour is brought to the attention of the management and corrective action taken, the less damage will ultimately be done. And the more likely it is that the public spotlight will be avoided.
The whistleblowing channel should therefore not be approached as an administrative imposition, as, if implemented correctly, it can significantly support your organisation's risk management processes and help save time, nerves and money.
I would be happy to tell you more about the definition of the process, as well as the training of the case managers. You can book the most convenient online appointment for you directly from our calendar:
See you soon!
Erika Heiskanen, Partner