“How many whistleblowers did the Feds ignore? In the Wells Fargo case, about 700.” After reading this headline from an April 2017 USA Today article, would you feel more or less inclined to report misconduct in your company? Did the practices at Wells Fargo discourage or encourage people in the future to come forward? Not feeling heard or formally acknowledged are two ways employees lose trust in hotlines. Ryan Hubbs shared these examples and more in his session, “Why No One Calls: Top 10 Factors Leading to Hotline Distrust” today at the ACFE Global Fraud Conference.
Hubbs, CFE, CIA, CCEP, CCSA and Global Internal Audit Manager, Data Analytics at Schlumberger, shared a video showing a room full of patients waiting to be seen by a doctor. Several of the patients were actors and one woman was the test subject. The experiment was to see if she would conform to the others’ behavior despite it making no sense whatsoever. Every time a short beep sound was heard, all of the actors would stand up. In the beginning, the woman looked around bewildered and confused. But, by the third time a beep was heard, she stood up as well. She conformed to what the actors were doing simply because the larger group was doing it. This illustrated our natural inclination to follow the herd. “When we are asking someone to report an issue, we are asking someone to go against the herd,” Hubbs said. “How do we combat that?”
Hubbs went on to highlight the top 10 factors that can lead to a hotline distrust:
- Employees don't understand the system
- Inadequate resources and poor program design
- Lack of personalization of an employee's concern
- Improper handling and lack of training
- Management involved in hotline
- Too many reporting mechanisms
- Too much emphasis on "credible" complaints
- Obstacles of negative incidents and retaliation
- Inconsistent outcomes
- Actions speak louder than words
But, have no fear. While there are specific reasons why people don’t call a hotline, according to Hubbs, there are just as many tips (see what I did there?) on how to effectively build trust in a hotline reporting program.
Hubbs recommends the following:
- Training and awareness. An organization should continually strive to help employees know how the hotline-reporting program works, why the organization believes in it, who operates it and why it's a critical part of the compliance culture. Organizations should include hotline frequently asked questions (FAQs) and answers in all employee new-hire and supervisor training.
- Ongoing communication. Communication about a hotline-reporting program, recent compliance issues and messages from management should be routine and commonplace.
- Accessibility. Information on a hotline program and how to report a concern should be within one click of the organization's intranet or external website. An organization should communicate program information in as many languages as necessary to provide coverage.
- Transparency. Prominently display your organization's hotline-reporting and investigation process including the expertise and contact information of your trained investigators, what employees should expect, plus the organization's responsibilities to cooperate and protect against retaliation.
- Proficiency and objectivity. Those who manage the hotline and investigation processes should be technically proficient, professional, well trained and experienced in handling reporting of concerns. The organization should also install adequate systems, processes and technologies to support the investigators and, ultimately, the employees.
- Assessment. Ongoing assessments should include how employees can view the program, independent reviews conducted by internal audit or external professionals, and disclose all complaints and resolutions with external auditors.
Hubbs suggested that companies should build and model a repetitive habit. If one person calls a hotline and experiences the ideal scenario of reporting a concern or irregularity, then that will become habit, and others will follow suit. Just as in the video example, the herd will actually lead the way for a positive habit, a habit that could stop fraud in its tracks.