IMPLEMENTATION

PURPOSE

Be clear on why the service is to be used and the difference between other options, such as grievance, emergency service or Employee Assistance Program.

If the service will include customers and suppliers, be clear on why the service is to be used and the difference between other options, such as customer complaint area or customer service department.

The best way to communicate the purpose of the service is with an Implementation Advice. We offer templates to assist in developing the awareness of the service.

Set the service level for your business. Our experience is that businesses have:

  • disclosures of 1 per 50 people
  • report of 1 per 250 people

Organizations where employees trust management and do not fear retaliation tend to experience lower rates of disclosure because the internal systems and controls ensure the business identifies an issue early so that it can be rectified as quickly and at low cost.

ESTABLISHMENT

Our service is designed to:

  • Support the business culture
  • Be part of your business improvement process
  • Augment the effectiveness of other standards, code of conduct and training

A code of conduct outlines the operating principles and serves as a guideline of the expected behaviour of each employee. Where this standard is not being met and/or the internal systems and processes are not working, an alternate avenue should be available to ensure the business can:

  • Check the systems and processes are effective
  • Identify systemic and system issues
  • Make appropriate improvements
  • Where necessary, address the behaviour of individuals

Whistleblower protection must be clearly communicated to ensure compliance with the law and for the overall effectiveness of the program, this includes strong protection from retaliation such as dismissal, demotion or denial of opportunities for advancement, as well as setting out the potential repercussions for those who retaliate against a whistleblower.

ROLES

Top Management ensure they are clear on the value of the program and demonstrate this through well documented policy, procedures and discussions. This should be reinforced through other communication, such as Meeting Agendas, Team Discussions and Updates.

Employees can report a concern 24/7.

Primary Contact manages the contract and service administration for the business.

Designated Recipient receives each report for the business. There may be more than one. For example fraud and accounting matters may be sent to an independent board member.

Case Investigator manages all information gathering by WBS to ensure that the Case Reporter can prepare the Report. This activity is through an anonymous dialogue.

Case Reporter prepares the WBS report and forwards the report to the Designated Recipient.

Service Manager prepares quarterly and annual reports, responds to queries about a report.

EFFECTIVE ACTION

Confidentiality and anonymity are critical factors to obtaining accurate information, so the business should ensure the barriers to reporting are as low as possible by:

  • Using a Web Portal that can retain confidentiality and anonymity
  • Explaining how well the disclosure and the person making the disclosure are protected
  • Avoiding phone and email as forms of notification
  • Avoiding other actions that might compromise confidentiality and anonymity
  • Using an external service to create multiple separations between the person disclosing and the organisation receiving
  • Avoid using internal Legal, Audit or HR functions as the first point of reference
  • Avoid recommending the first step in raising the concern, should be with a manager or colleague

The program should ensure everyone is aware of the service (employees, contractors, visitors), with the information being available:

  • In the Code of Conduct
  • In the Handbook and on wallet cards
  • During orientation, induction and re-induction programs
  • As part of all training programs offered to employees

Once the Designated Recipient has received the report, it is important that the information in the report be acted upon in a timely manner. The business should have clear rules on:

  • Access to the information
  • Performance Indicators for actioning reports
  • Providing advice to WBS when the report has been actioned

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