Let's be honest — it takes a lot of courage as an employee to report anything to the company you work for. The courage to report something that could come back to haunt you is next level. As stewards of the organization's culture, it’s our job to help employees feel safe and comfortable raising a concern. And we can make sure that our teams who hear employee concerns know how to handle them.
When I worked as an in-house ethics director, one of the areas I was most concerned with was the triage of the hotline. My team soon realized that when an employee called in with a report, we were getting only one piece of the puzzle. In some cases, the employee was afraid to say what was really on their mind. In others, something the employee said hinted at a larger cultural issue.
Emails would come in “letting us know” something seemingly benign, such as overhearing that a team was going to dinner with a vendor. After a little digging, we might find out that the issue was much bigger, such as a planned meal and drink feast for 15 that was waaaay above the policy allowances.
In these situations, it’s the Ethics & Compliance team’s job to look at the subtext of what’s being reported, ask questions, and discover what else could be going on — “the story behind the story.”
What does that look like? In my experience, there are five key things your team can do to find the story behind the story:
1. Be approachable.
With all the political backlash against whistleblowers in the media, this is more important now than ever. Address employees’ fears head-on. Reassure them that raising concerns is still the right thing to do and that the company will not retaliate. Present the Ethics & Compliance team as a resource for employees. You’re there to help them do their job well and stay out of trouble — not to be the cops.
Often, this means starting the conversation, so employees can put a name and a face to the team. Start by listening. Open up a two-way conversation by asking employees about their concerns. This can be as formal as a company-wide survey or as casual as a conversation in the break room. When you do live training, stick around after the session to answer questions and chat with employees.
2. Train the people who manage the helplines, hotlines, and email boxes to look beyond the surface level of the report.
Finding the story behind the story means doing some detective work. When managers or compliance officers hear an employee concern, they should ask themselves:
- Have I heard this story before? About these people or about this team?
- What is this telling me about how employees understand — and act on — our Code and policies?
- What is this telling me about the dynamics of this team or division? (Use analytics to see if there are trends that help fill in the picture.)
- What is the tone of the report?
- Have any of our partners received a similar report? (See #3 below.)
Don’t exchange emails back and forth. Get the reporter on the phone and have a conversation. You’ll learn more in a few minutes on the phone with someone than you will trying to read between the email lines.
3. Look for reports from partners and places you didn't think of initially.
This could be any team member with a compliance, security, or safety email address, or it could be middle managers and team leaders. Some employees are more comfortable reaching out to an individual they know rather than calling the hotline or submitting a report online. Are you getting the data from those teams? Be sure to include these groups in your training. Establish communication channels and make sure they know what to do with a compliance or ethics report.
Constantly talk to your partners about what you're doing and why. They are going to be your advocates, too. Tone from the top is important, but it's the middle where the behavior change can occur the fastest. Make sure these teams walk the talk. If they see or hear something — even if it’s not a formal report — they should know you expect them to take action.
4. Show employees you’re listening.
Thank them for sharing their concerns and reassure them that the company wants to make it right. Be respectful of their privacy by only bringing in other people if you have to. If you don’t know the answer to something, tell them you don’t know, and get back to them with an answer.
Most importantly: Take action and share the results (when you can).
Of course, sharing results of investigations can be tricky. There are privacy and employment concerns and, honestly, we as a profession just haven’t been too comfortable with sharing results in the past. “Thanks for reporting your concern, we’ve got it from here” has been the mantra.
It’s time to challenge that status quo. Talk with leaders on a regular basis (not just when something serious has happened) about what’s happening in their organizations and ask for their help in training and changing behavior. When appropriate, ask employees to share their stories — in a clip, a communication, a team meeting or as part of a training. If you ask employees for their feedback in a survey, always send a follow-up communication to share the actions the company has taken as a result.
5. Test the system.
Run test cases — fake reports with real names and real concerns — through your system to see how your teams handle them. Test your HR, ER, Asset Protection, and Security teams, along with any other channels where a whistleblower concern could come into the organization.
You may get some pushback at first. The GC will shake when you tell them you want to run "some test cases" through the system. The teams may be mad when they realize they’ve been tested. But remember the goal here is to make employees as comfortable as possible in raising a concern, which means making sure your partners know how to recognize an ethics or compliance concern and how to manage it. It’s best to do that now, in a controlled testing environment — rather than later in discovery while prepping a case.
The most likely outcome is a series of conversations with partners about why you think something should come to the Ethics & Compliance team instead of their team.
Remember: Don't give in to pressure from above and around.
Employees are counting on leaders and certain roles in the organization to be stewards of the culture. Ethics and compliance folks — that's us. How can we expect others in the organization to act on something that doesn't seem right if we don't? Employees are counting on you to see the story within the story and help them.
Use your voice to help others find theirs.