Implementing a strong ethics and compliance program takes thoughtfulness, diligence and a bit of creativity. To launch a successful program, the first order of business must be to ensure that the program is thorough, well promoted and has the total support of management.

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Endorsement from the top down is critical to the success of any ethics hotline. Employees will not come forward unless they believe that management will be receptive to them and will take action based on the report.

Publicize and Promote

One simple reason why employees don’t report misconduct, is that they don’t know where to go and/or how to file a report. Often, companies bury their hotline process deep within the employee handbook, and that ends up being the only mention of it anywhere within the organization.

A successful program ensures that employees are:

• aware of their options to report
• offered numerous methods to report
• trained on the code of conduct and what types of behavior they should report
• assured of no negative consequences

Training and Examples

“Lunch and learns” are a great way to introduce your system. Allowing staff to use role-playing to demonstrate what types of behavior are considered unethical (and should be reported) is an excellent tool to reinforce your code. Many companies offer e-training videos that include examples on what is considered unethical in business. Oftentimes employees need concrete examples in order to digest what a hotline should be used for.

Using sanitized case studies is another great way to demonstrate and clarify the types of misconduct that the company would expect to be reported. These can be included in the corporate newsletter, uploaded to the intranet, or even posted in the staff room. Having posters visible and distributing wallet cards with the contact information for the hotline are other ways to support the program.

Multiple Methods of Reporting

One of the best things you can do to encourage reporting of misconduct is to give your staff options. A hotline is good, but having multiple methods of reporting is better.

Other good options include:

• web portal
• customized email address
• fax
• “snail mail”
• suggestion/complaint box in the staff room

When a staff member is not comfortable reporting to their direct supervisor or the human resources staff, you must provide alternative solutions for them to come forward. Accordingly, you must give them the channels to be able to deliver the goods. In the end, everyone wants to do the right thing.

24/7/365 Access

24/7 access is essential. Often employees are nervous, uncomfortable and scared when coming forward. Making the decision to report wrongdoing is fraught with anxiety and trepidation. They may fear exclusion, retaliation and losing their jobs.

In order to provide as much flexibility as possible, you must ensure the hotline is available 24/7/365. The moment a staff member sums up the courage to come forward, you need to ensure that there is a trained operator to take the call.

No Retaliation

First and foremost, anti-retaliation policies must be part of your code of conduct. There can be no retaliation tolerated at any level. This is important for creating a successful system, but also key to supporting the company’s goal of emphasizing a culture of integrity.

As part of your anti-retaliation strategy, you must ensure that (from the most senior management level down to the line staff) the expectation exists that it is their obligation to come forward if they witness misconduct. Part of this mutual obligation between employee and company is that they will be protected and (if appropriate) recognized for their commitment to the organization by coming forward.

Culture of Integrity

The goal is to encourage staff members to report wrongdoing, but also to create, nurture, and promote a culture of integrity. Employees will feel empowered to come forward if they know their company is committed to the protection of not only its assets, but also to the protection of its people because, ultimately, the most important asset a company has are the people who work there. A reporting hotline can be the best tool a business has through which to create a better work environment, a stronger employee culture and, most importantly, a better business.