Four Phases of an Effective Whistleblower Program
1 ASSESSMENT
Evaluate Needs
Establish Protocol
Identify Reporting Mechanisms
Select Oversight Board
2 BUILDING
Train Operators and Oversight Board
Update Policies and Procedures
Write Board's Charter
3 PROGRAM RELEASE
Distribute Notices
Define Program Release Mechanism
Meet with Employees
4 PERFORMANCE MONITORING
Meet with Oversight Board
Review Performance Reports
Survey Employees
10 Steps to Assessing a Whistleblower Program
1. REVIEW THE PROGRAM'S PROTOCOL. Make sure the protocol provides clear and specific guidance on what to do and whom to contact in response to a range of possible scenarios.
2. EXAMINE ALLEGATION FILES. Verify that the information in the allegation files is consistent and complete so investigations are not impaired. Confirm that the whistleblower's identity was protected and that a key or code instead of the whistleblower's name was used during the investigation.
3. REVIEW THE COMPOSITION AND ROLE OF THE OVERSIGHT BOARD. The organization's legal counsel, director of internal auditing, chief financial officer, human resources director, and corporate controller should be members of this board. They should be senior officers who meet frequently, are active in their oversight capacity, and are prepared to take quick and decisive action in the event of inappropriate activities.
4. VERIFY THE AUTONOMY OF THE PROGRAM. Examine the program's budget for sufficiency and make sure the program's manager is independent. There should be a direct reporting line to the oversight board and the audit committee.
5. REVIEW PERFORMANCE REPORTS. Are performance reports accurate, timely, and useful? The audit committee and oversight board should agree on the content and frequency of reports, which should include at a minimum the number of allegations received, the number substantiated, a ranking of the risk/impact to the organization, and turnaround times from reporting to investigation and investigation to resolution.
6. VERIFY THE ADEQUACY OF THE PROGRAM'S BUDGET. Is the budget adequate to hire enough competent staff to handle whistleblowers' calls and to conduct professional investigations? A single individual should not have the ability to reduce the budget because the act or threat of cutbacks could impair the program's effectiveness, independence, and objectivity.
7. REVIEW THE EMPLOYEE MANUAL AND CODE OF ETHICS. Make sure the whistleblower program is referenced in the employee manual or the code of ethics. This will add to the program's legitimacy and make it a permanent component of the corporate governance infrastructure. Keep the contact information up to date and make sure it's clear that retaliation is explicitly forbidden.
8. VERIFY ACCESS TO THE PROGRAM. Are the phone, fax, and e-mail connections operational and attended to around the clock? Is the staff assigned to the overnight shift really there? Was a new facility opened somewhere that is not covered by the original access avenues?
9. CONFIRM THE QUALIFICATIONS OF THE STAFF. Make sure the attending staff is qualified, especially if there has been turnover in the group. The staff's responsibilities are not limited to data entry because if staffers are rude, insensitive, or careless they are likely to collect insufficient or inaccurate information, limiting the chances of conducting a fair and thorough investigation.
1 ASSESSMENT
Evaluate Needs
Establish Protocol
Identify Reporting Mechanisms
Select Oversight Board
2 BUILDING
Train Operators and Oversight Board
Update Policies and Procedures
Write Board's Charter
3 PROGRAM RELEASE
Distribute Notices
Define Program Release Mechanism
Meet with Employees
4 PERFORMANCE MONITORING
Meet with Oversight Board
Review Performance Reports
Survey Employees
10 Steps to Assessing a Whistleblower Program
1. REVIEW THE PROGRAM'S PROTOCOL. Make sure the protocol provides clear and specific guidance on what to do and whom to contact in response to a range of possible scenarios.
2. EXAMINE ALLEGATION FILES. Verify that the information in the allegation files is consistent and complete so investigations are not impaired. Confirm that the whistleblower's identity was protected and that a key or code instead of the whistleblower's name was used during the investigation.
3. REVIEW THE COMPOSITION AND ROLE OF THE OVERSIGHT BOARD. The organization's legal counsel, director of internal auditing, chief financial officer, human resources director, and corporate controller should be members of this board. They should be senior officers who meet frequently, are active in their oversight capacity, and are prepared to take quick and decisive action in the event of inappropriate activities.
4. VERIFY THE AUTONOMY OF THE PROGRAM. Examine the program's budget for sufficiency and make sure the program's manager is independent. There should be a direct reporting line to the oversight board and the audit committee.
5. REVIEW PERFORMANCE REPORTS. Are performance reports accurate, timely, and useful? The audit committee and oversight board should agree on the content and frequency of reports, which should include at a minimum the number of allegations received, the number substantiated, a ranking of the risk/impact to the organization, and turnaround times from reporting to investigation and investigation to resolution.
6. VERIFY THE ADEQUACY OF THE PROGRAM'S BUDGET. Is the budget adequate to hire enough competent staff to handle whistleblowers' calls and to conduct professional investigations? A single individual should not have the ability to reduce the budget because the act or threat of cutbacks could impair the program's effectiveness, independence, and objectivity.
7. REVIEW THE EMPLOYEE MANUAL AND CODE OF ETHICS. Make sure the whistleblower program is referenced in the employee manual or the code of ethics. This will add to the program's legitimacy and make it a permanent component of the corporate governance infrastructure. Keep the contact information up to date and make sure it's clear that retaliation is explicitly forbidden.
8. VERIFY ACCESS TO THE PROGRAM. Are the phone, fax, and e-mail connections operational and attended to around the clock? Is the staff assigned to the overnight shift really there? Was a new facility opened somewhere that is not covered by the original access avenues?
9. CONFIRM THE QUALIFICATIONS OF THE STAFF. Make sure the attending staff is qualified, especially if there has been turnover in the group. The staff's responsibilities are not limited to data entry because if staffers are rude, insensitive, or careless they are likely to collect insufficient or inaccurate information, limiting the chances of conducting a fair and thorough investigation.
No comments:
Post a Comment