Ring. Ring. Ring…is anyone there?  Can you hear me now?  Have I reached the right number?  Nearly everyone with a compliance program has some sort of reporting mechanism, whether it’s a formal whistle-blower hotline or an email address for the compliance department.  But how good is your whistle-blower hotline?  To find out, answer these three questions.

1.     Who can call?

Do you want to hear about the ethical concerns of your employees?  Of course.  What about the concerns of your suppliers?  How about the compliance concerns of your customers?  Yes?  Yes.  Knowledge is power.  While it’s true that if you extend the availability of your whistle-blower hotline to the outside world, you may get some spurious complaints, a real concern that you can properly investigate is worth the irritation of a couple of consumer gripes about your product.

A mature compliance program’s whistle-blower hotline should be available to:

·       Your employees

·       Your suppliers

·       Your business partners

·       The public

Extend the reach of your hotline so that everyone who needs to contact you can do so.

2.     How can they communicate with you?

Some people hate talking on the phone.  Others are so inundated with email that they can’t stand to look at their screen.  Some want to come talk in person.  Others are concerned because they want to communicate in their own language instead of working to discuss complicated issues in English. 

How can people communicate with you?  A mature compliance program’s whistle-blower hotline should:

·       Have a mechanism for calling

·       Have an online form for inputting concerns

·       Have an email address to write to directly

·       Be available in as many languages as are (a) used in your company, (b) used in the areas of the world in which your products are available, or (c) used where your offices are located

·       Include a mechanism for calling back so people can get an update on their complaint

By making it easy for someone to communicate, you’ll make it easier for you to get the information you need to do your job properly.

3.     Where do they get the information?

It seems like some companies want to keep the contact information for the whistle-blower systems concealed.  Is your whistle-blower phone number buried in the bottom of an intranet page no one ever sees?  If you Google your company’s name and “whistle-blower hotline,” does anything relevant come up?  People can’t report if they don’t know where to do so. 

A mature compliance program’s whistle-blower hotline should:

·       Be easily available from an obvious page on the Intranet (e.g., linked from the homepage)

·       Be available in all languages if there are multiple intranets for different offices where languages other than English are used

·       Be available on your company’s website, or linked to your company’s website

·       Be advertised in your company’s offices (e.g., in the break room on a poster)

The answers to these three questions can tell you everything you need to know about how your whistle-blower hotline is really working.  Knowledge is power, and you’ll never know what you need to know if people can’t report easily and confidently.  Implement the best practices above and when someone rings…you’ll be right there to listen.