Is your hotline working for you? In an article, entitled “Promoting Effective Use of the Company Compliance Hotline”, José Tabuena provided an excellent example of the power of a hotline. He provided a case study of a company which had not integrated its IT function into its regular compliance and ethics training programs. As such there were zero calls into the hotline by IT employees. This dynamic was changed and IT was integrated into the company’s regular compliance and ethics training. Thereafter, the hotline received several calls from IT employees indicating where there were two major areas of complaints. The first area regarded family members who were hired and perceptions of favoritism. The second related to allegations that certain managers were manipulating data to maximize their bonuses.
This case study demonstrates the power of a hotline. The company’s Compliance Department “established the credibility of the helpline as a resource to raise issues and report misconduct. The concerns regarding nepotism and conflicts of interest were taken seriously, and although the violations were not as widespread as the calls indicated, the review went a long way to clear the air.” Equally important, the helpline proved to be a successful management tool as well. The company was able to manage potential compliance issues and improve employee morale.
Three key takeaways:
- Hotlines can be powerful tools for the compliance professional.
- Simply because you have no hotline complaints does not mean you do not have any compliance or ethics issues which need review and resolution.
- Adequate follow up is a key part of overall hotline effectiveness.
