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 that 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 that there were two major areas of complaints.

The favoritism problem. HR led an investigation that included questioning all IT managers about their direct reports and employees of their unit. The company determined that there was only one instance of a manager hiring a family member (a brother-in-law), but that person did not report to the manager and was in a different section of the IT organization. This finding made clear that there were misperceptions in the IT department, which affected the department’s morale.

Manipulation of data for bonuses. The company used the hotline to obtain more information from the callers on “isolating the metrics and the managers in question.” It was determined that the bonuses of a select few IT managers were indeed influenced by a questionable data source, which was controlled by a non-manager with minimal oversight and controls.

Basic tenets of an effective hotline. This case study provided three key tenets of an effective internal reporting system:

• First, a helpline is of no value if the workforce is not aware of it.

• Second, the ethics and compliance office obtained support from the Chief Information Officer (CIO) which likely influenced the success of the training and communications delivered by the ethics and compliance staff.

• Third, the awareness of the helpline is not sufficient to ensure success as you must make sure that issues and allegations are addressed and investigated.

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.

 Three key takeaways:

1. Hotlines can be powerful tools for the compliance professional.

2. Simply because you have no hotline complaints does not mean you do not have any compliance or ethics issues that need review and resolution.

3. Adequate follow-up is a key part of overall hotline effectiveness.