Reduce Your Whistleblowing Reporting Risks
How Standardising your Reporting Process could Significantly Mitigate the Risk of Wrongdoing in Your Organisation
A whistleblowing 'speak up' solution is an important need to have in place in your organisation.
A clear whistleblower process helps your employees report concerns easily and confidentially; and allows you to identify any 'hot-spots' or warning signs in parts of your organisation.
Only by early detection can you protect your organisation from wrongdoing escalation, reputational damage, and financial risk.
There are several key components that come together to create a strong whistleblowing solution in any organisation.
- A variety of employee reporting channels to report a concern (e.g. phone and web)
- The ability to blow the whistle on wrongdoing anonymously or semi-anonymously
- A case management portal that enables you to effectively process reports and manage concerns and communicate with the reporter
- Policies and procedures that allow you to effectively manage your reports in an ethical manner.
A key focus of your whistleblowing procedures to get right should be how to conduct your investigations into any reports raised, ie: when a suspected wrongdoing is committed or reported investigators have a duty to conduct an effective and ethical investigation.
At Safecall, we believe it is crucial you have a standardised procedure for investigating reports which is both consistent, and held to a high standard:
"The purpose of any investigation is to objectively and reliably make a determination of the facts and circumstances of reported or suspected wrongdoing affecting
the interests of the organisation".
So, what should your Investigation Framework include?
We advise your investigation documentation should focus on and clearly offer a framework in the following areas:
- Your Whistleblowing Investigative Strategy
- Your Investigative Process framework
- A clear guide and a framework for conducting the investigation
- Interview Strategy and Planning framework
- A standardized structure for the investigation report
What are the benefits of an Investigation Framework?
1) Having a standardised procedure will benefit your organisation in a number of ways.
Firstly, having a clear whistleblowing framework will save you, and your investigators time.
This is because whoever is assigned to investigate the report will not need inducting, or training on best practice.
They will have a clear blueprint to follow with timelines and expectations presented to them, along with best practice conduct which in theory should guide them from start to finish. This also means that you can assign the right investigator for the report, without concerns about their experience.
2) A clear whistleblowing report investigation framework allows you to be consistent across all reports raised.
This will significantly minimise the risk of personal bias, verification bias, availability error or limited personal experience effecting the fairness and quality of an investigation.
It will also help you to establish if any investigation should be conducted internally, or externally.
Conducting a good quality investigation consistently naturally reduces the risk of any backlash in the future from legislation, rules or regulations and any further scrutiny at a later date.
3) Providing detailed and consistent guidance is also the key for creating and maintaining a healthy 'Speak Up' Culture.
Every reporter should feel supported, safe and valued throughout the process of their report being investigated.
By ensuring the treatment of every report is positive, fair and consistent will go a long way in benefitting the internal view of your culture around speaking up. Simple, consistent steps such as saying 'thankyou' to a reporter for raising their concern should not be overlooked.
Word of mouth is a big factor in the success of an organisation's whistleblowing culture, so always be mindful of creating a positive experience for the reporter.
Likewise, it is important to ensure that whistleblowers receive consistent notifications of the stages of their concerns for them to be assured that their concerns will be taken seriously.
A investigations guide helps ensure this is common practice, and that you are capitalising on good 'word of mouth' PR.
4) Compliance with EU Whistleblowing Directive- Creating a standardised procedure for investigations is also a key component of becoming compliant with the new requirements set out in the EU Whistleblowing Directive.
Examples on ways in which the directive affects how we now run investigations include:
- Organisations need to give clear objectives for how long an investigation should take. Including, how often and how soon feedback will be given to the whistleblower.
- Processes such as these must be adhered to in order to remain compliant with the Directive. Having a robust framework is the first step in ensuring your organisation is always compliant, limiting any financial risk from fines.
What is right for your organisation?
There are a lot of areas of an investigation framework that are best practice in any organisation.
If you would like to know more about the best practice and would like a framework to follow please don't hesitate to reach out to the Safecall team. We can organise for you to join one of our regular Investigation Training Courses, which include an investigators' handbook, covering everything you need to know.
Once you have your framework, we recommend regularly reviewing it to ensure it is still the best practice, and that it takes onboard any feedback you have received from investigations.
We believe you should also share anonymised case studies within your organisation where appropriate. These show that, thanks to a whistleblower report, harm has been stopped or a process has been improved and help promote a positive attitude toward whistleblowing.
It is also important that any learnings from whistleblowing investigations are used throughout the organisation and any improvements should be communicated to the relevant teams.
Key questions to ask to consider if you need to revisit your whistleblowing investigation framework
1) Do you have a secure system that allows your employees to raise reports in a consistent way? (If not, speak to us... we can help.)
2) Are Line Managers and Senior Leaders aware of their roles and responsibilities in relation to the whistleblowing reports, and any whistleblowing investigations that may be undertaken?
3) Does your Investigations Framework include, at a minimum, clear guidance on:
- Support for the whistleblower?
4) Does your internal audit team review your organisations investigations regularly to ensure that process is being followed consistently?
5) When a new report is raised do you consistently provide acknowledgement and thanks to the reporter, and explain how the report will be dealt with (within seven days)?
6) Do you provide updates to whistleblower throughout the investigation?
7) Is there a clear, documented process for next steps to resolve whistleblowing concerns after investigation? For example, addressing and resolving a wrongdoing?
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.