Employee Hotline, Part III

Who Gets The Call?
One of the most important parts of planning the hotline is deciding where to send information that is received. A system of rules must be developed to determine what happens to information after the call.

Human Resources typically receives the bulk of the complaints reported, but there is a need for "checks and balances." Dual distribution of complaints can be a helpful practice for ensuring that complaints are not overlooked. For example, reports of harassment would be sent to Human Resources as the primary recipient of the information, with a copy to the Ethics Officer or the Auditor as the secondary recipient. The dual handling acts as a protective device in case a report is sent to the accused party. If a report is received by only one person, and that person has a motive for preventing an investigation, the system is vulnerable.

Complaints having potential legal implications, like allegations of discrimination, should be sent to Legal (or whoever is functioning as legal liaison) and Human Resources to ensure that both areas are involved in the investigation. Depending on the financial institution's structure, there may be other interested individuals. For example, there may be a Risk Management Officer, a Safety Officer or a Security Director who should receive reports of unsafe working conditions. Similarly, Loss Prevention, Security and Audit should receive reports regarding internal theft and reports of vendor fraud. Security should get reports of potential workplace violence.

Sample Report Distribution Structure ISSUE POTENTIAL RECIPIENTS Employee Mistreatment Human Resources, Auditor External Fraud
(including Vendor Fraud) Human Resources, Auditor, Security Officer Accounting or Procedure
Irregularities Auditor, Legal or Legal Liaison,
Security Workplace Violence Security, Legal, Human Resources Employee Theft Auditor, Security, Human Resources
Emergency Procedures
Another extremely important aspect of the planning process is determining procedures to be followed when a time-sensitive issue is reported. The hotline implementation group must agree upon a list of topics that are sufficiently critical to require immediate notification 24 hours a day.

Although many hotline reports do not require immediate notice 24/7, there are certain high-risk situations that may be reported. These incidents or allegations should be considered prior to hotline implementation, so the management team has a shared understanding of how such a situation will be handled.

Reports generally resulting in immediate notification include:

Threat of violence or physical harm to employees or customers
Threat of business interruption
Notice that a high risk incident is expected to happen (such as a bomb threat)

In financial institutions, due to the nature of our business, other impending incidents also require prompt attention. Such as:

Fraud
Falsification of records
Release of proprietary information
Theft
Media inquiries

When a report is received that is designated for emergency procedures, the hotline provider should call the representatives on the planning group immediately based on a pre-determined list of home and cell phone numbers of key personnel. In the case of a report received at 11 p.m. on a Friday night, immediate notification enables you to take preventative action rather than discover the report on Monday morning, which may be too late to address the issue.

Communication: The Key To Hotline Effectiveness
Once the hotline processes are defined and operational details are in place, the communications plan begins. Hotline communications should be part of a broader program of defining the financial institution's ethics policy and promoting ethical behavior in the workplace. Communications that promote ethics and encourage use of the hotline not only help detect issues, but should also help prevent them by creating a culture of ethical behavior.

As with any communication that seeks to modify behavior, there are strategies that help ensure the program's success. These include:

"TOP DOWN" - Is the purpose of the program communicated and supported from the very top? Visible support from top executives and administration is especially critical. If a program is seen as unimportant to top management, employees may disregard the communication.

SHARED UNDERSTANDING - Are the roles of each participant identified and understood? If not, the process will break down.

DOCUMENTATION - Is there a way to measure and document the program? For example, is there a way to document that each employee has received information? Documentation can help evaluate the causes of a program's success or weakness, and helps "tweak" the process.

RECOGNITION - Is there a way to recognize positive performance? For example, if an employee reports theft, is there a way to reward him or her financially? If a hotline call inspires a change in policy, publicly applauding the person who drew attention to the situation demonstrates the usefulness of the program. This, in turn, inspires more participation.

FORWARD STRATEGIES - Is there a plan for evaluating and periodically redirecting the program? Thinking ahead about the future direction of the program ensures its success.

To be continued. Our thanks to THE NETWORK for providing us with Best Practices in Ethics Hotlines and for their permission to use it.

Copyright © 2005 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 15, No. 8, 8/05