A whistle blower is a person who exposes secretive information or activity that is deemed illegal, unethical, or not correct within a private or public organization.
Whistle blowing is considered as an essential control from regulatory perspective. Regulations mandates certain organisation to have a formal vigil mechanism (e.g. Listed companies). Governing bodies including Audit Committee, where exist, are required to review the incident raised and their outcome.
Here are top 5 consideration which management need to consider while going for a whistle blower/ vigil mechanism for its success (from management’s perspective):
- Who will be covered?
Who or which parties can raise an complaint? Many organizations restrict the vigil mechanism to employees only. Some extend to their vendors and some extend to world at large. Based on coverage planned, the mechanism to raise a complaint is decided.
2. What complaint to be covered/ require further investigation:
Once deployed this tool can be used in any manner. It can be used to raise compliant, raise unhappiness, known issues, etc. Some management want to cover fraud cases, some want to cover everything. Its important to define categories of complaints so that people know that “no promotion given” should not be an issue, unless they believe that manager had favored their kin. “Implementing a system” is not an issue, however buying a system at inflated price for a bribe is an issue.
3. Where an complaint will be raised?
What mode of raising a complaint to be offered? There are various modes of raising an complaint. E.g. Email, phone number to call, hotline, fax number to fax, a website to raise complaint, postal address, etc. There are merits and demerit of various channel along with cost involved.
4. When an complaint needs to be raised?
Some time people will be raising an complaint when something is getting discussed/ planned. Organization need to define guidelines to cover situations. In the absence of them, there is a risk that people will raise complaint regarding a future event which will be their imagination.
5. Who will be the person who will receive all the complaint?
Who will be the person who will receive all the complaints? He/ She can be Legal, HR, Company secretary, CEO, Chairman, Audit committee chairman, Internal Audit. It should be received at a level which is sufficient to ensure a fair treatment to the complaint.
6. What to report?
Organization need to decide what they want to report. Do they want to report total number of cases? Or they want to report number of complaint investigated.?
Looking at news headlines now a days, it is becoming more and more important to implement whistle blowing policy holistically. i.e. covering everyone, giving multiple channel of communication, an ability to track compliant, protection to honest whistle blower as well as deterrent for frivolous whistle blowers with oversight from governing body of the organization.
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Call for action:
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(Disclaimer: The views expressed constitute the opinion of the author and the author alone; they do not represent the views and opinions of the author ’s employers, supervisors, nor do they represent the view of organizations, businesses or institutions the author is, or has been a part of.)
