How to: Organise a whistleblowing programme

Whistleblowing programmes are the channels through which your people can raise concerns about anything from health and safety to fraud. In the best-case scenario., these channels become a safety net for risk management. But would your net catch the right risks?

Whistleblowing has some negative connotations and is perceived by many as only a means to identify problems. Building a broader strategy, however, allows you to focus on positive reporting: a ‘speak up’ strategy incorporating the full range of ways employees can seek guidance from and raise issues to line management.

So, how does this help with low-probability, high-impact risks? An open culture is fostered by encouraging employees to trust and communicate with their line managers. This way, issues will come to light sooner and can be resolved.

Staff should feel more comfortable raising difficult issues, giving you a chance of identifying ‘black swan’ events at an earlier stage. And not only will your net catch the risk issues, but you will foster a positive attitude in your people, which may have indirect benefits to your bottom line.

The biggest challenge is getting people to buy into the open culture. How do you make it work?

1 Secure commitment from the top

In an open culture, people with serious concerns are more likely to use other speak-up arrangements, rather than formal whistleblowing mechanisms.

And an organisation’s general attitude to business ethics is cultivated by its chief executive, board and senior management through the policies they design and the examples they set. Senior management must also be involved, supporting the implementation and monitoring of whistleblowing reports and outcomes.

2 Develop an outcome-based policy

Be clear about the purpose of your whistleblowing policy and how it fits into a broader speak-up strategy. This will make the system more useful and thus used more widely. Identify who will be able to use your reporting system.

This is a great way of managing your third-party and supplier risk. It can help with Bribery Act compliance, for instance, as well as strengthening your key relationships.

3 Choose the right mechanisms

Determine what combination of direct (through the management chain) and indirect (through an independent team) reporting mechanisms are needed and whether these will be in-house or through external service providers. Providing a range of reporting mechanisms increases the chances that people will trust at least one of the options.

4 Talk to middle managers

Effective communication, guidance and training must be in place to embed the programme. Often, the missing piece in an effective programme is the support of middle management. They can become disillusioned, feeling targeted by those below or unsupported by those above. Worse, they can be blockers to the system, increasing the risk of whistleblowers going public.

Appointing local champions within management can help with both communication and buy-in. Research suggests that where whistleblowers use a local champion, they report their concerns formally within the organisation constructively. Champions build trust and help direct issues to the right team.

5 Report, monitor, evaluate and adapt

If you don’t measure it, it won’t get done, but measure the wrong thing and the wrong thing will get done. Appropriate measures will change as your programme matures, so evaluate and adapt regularly. What balance of measures is right for you? The number of reports, investigations, convictions?

You get out what you put in. An effective speak-up strategy is a great way to build an open, ethical culture while maintaining your risk management safety net. Capturing good ideas as well as risks will not only protect the bottom line but will also build value in your business. SR

Rob Wilson is senior manager at PricewaterhouseCoopers’ forensic services practice