1.
How to Set Up a Whistleblower Hotline
Considerations, Communications & Consultation
Shannon Walker - President, Whistleblower Security

2.
Shannon Walker is the founder and CEO of Whistleblower Security Inc., an
ethics and risk management company with clients worldwide, that protects and
shelters organizations by allowing employees to anonymously report fraud,
embezzlement, harassment, and other workplace misconduct and ethics
violations.
Shannon founded WhistleBlower Security to assist organizations in creating a
more transparent and accountable environment for their employees and other
stakeholders. WhistleBlower Security delivers anonymous ethics hotline and risk
reporting services on a global basis meeting regulatory and compliance needs
and improving an organization's culture and commitment to long-term
sustainability and growth.
Shannon Walker

3.
“It takes many good deeds to build
a reputation and only one bad one
to lose it.”
• Benjamin Franklin

4.
FACTS
• 4 out of 10 people have said their
businesses have a weak ethical culture
• 62% were confident in their firm’s senior
leadership
• Nearly one quarter said senior managers
involved in misdeeds
Source: Ethics Resource Center, 2014

5.
FACTS
• 63% of those who witnessed misconduct reported
the wrongdoing
• More than one in five whistleblowers who reported
misconduct were retaliated against in some form
• 13% of employees felt pressure to compromise
ethical standards in order to do their jobs
Source: Ethics Resource Center, 2014

6.
Good Corporate Governance
• Protects both the company and employee
• Eliminates waste, loss, theft and identifies
sources of corruption and dishonesty
• Increases employee morale and engagement
• Limits liability for directors and managers

7.
Ethics & Compliance
• Reputational and financial integrity
• Shelter company and management from costly
litigation
• Global Regulatory Reach – FCPA, UK Bribery Act,
Dodd-Frank, SOX
• Improve corporate culture & increase shareholder
value

8.
Why?
• Compliance
• Best Practice
• Detect and Prevent Ethical Breach Occurrence
• Because You Should

9.
Effective Policy Development
• Key to consider existing corporate culture
• Creating Tone at the Top - Walk the Walk,
Speak the Speak all the Way to the Middle
• Clear, easy to understand policy
• Non-retaliatory in nature

10.
Policy Consideration
• Ensures decision making is consistent and sets
standards of ethical considerations
• Examine industry-specific risks to identify additional
fraud protection
• Policy need to have clear expectations and
anticipated outcomes
• Code clearly defines expectation of behavior within
the organization

11.
Impact of Hotlines
• Tips best method to detect fraud (over 40%)
• Impact of tips underestimated by fact so many
organizations fail to implement reporting systems
• Better you are at collecting and responding to fraud,
better you will be at detecting it and limiting losses

12.
Setting Up the System
• Average hotline volume amounts to 2-5% of employee population
annually
• Volume varies dependent on:
– Corporate culture
– Promotion and Training
– Confidence in management’s commitment
– Current issues facing company
– Past behaviors and reactions

13.
Outsource or Internal
• Cost effectiveness
• Availability
• Regional/National/Global Needs
• Training, promotion, responsiveness
• Anonymity is key but system must incorporate ability to
communicate with whistleblower
• Bottom line: Any system is better than none

14.
Outsource Vs. Internal
• In-house systems do not always provide the level of
confidentiality and protection of anonymity
• In-house system may not have requisite
sophistication that a third party system specifically
designed for this program
• Perceptions exists that management truly committed
if third party introduced

15.
Outsource Vs. Internal
• Voicemail can compromise anonymity by identifying the caller’s
voice – it is a never do!
• Trained hotline agents who are schooled in empathetic and
investigatory techniques
• Live agents much more likely to elicit important information
• Hotline agents will not be distracted by other duties
• 24/7/365 access

16.
Outsource Vs. Internal?
• Comprehensive back-end incident management system and
cataloging capabilities
• Reporting, analytics and holistic oversight
• In-house operations hampered by employee vacation, sick time,
other duties
• Marketing materials
• Translation/Interpretation requirements

17.
Claim
Receive
Analyze
InvestigateResolve
Report
Retain

18.
Decision + Implementation
Regardless of outsourced or in-house, implementation
priorities are:
– Code of Conduct Development
– Communication Planning Strategy
– Train, retrain and train some more
– Senior Management Engagement – Walk the Walk

19.
Launching the Program
Internal Work Requirements:
– Code of Conduct
development
– Toll-free lines set up
– Scripting
– Web portal development
– Email method set up
– Responsive workflows
– Anonymous dialogue
workflows
– Training in-house personnel
– Marketing & Promotion
Literature Development
– Language requirements

20.
Launch Part Two
Code of Conduct Introduced
Training
– Lunch & Learns
– Corporate Intranet and Newsletter
– E-training
– Role playing
– Sanitized case studies

21.
Reporting
• Ensure identifiable metrics are set up
• Real-time capabilities
• Feedback and adjustments
• Opportunities for education on both system and what ethical
breaches are within your organization

22.
“Berkshire would be more valuable today if I had put in a
whistleblowing (hot) line decades ago. The issues raised
are usually not of a type discoverable by audit, but relate
instead to personnel and business practices.”
Warren E. Buffett
Chairman of Berkshire Hathaway
2005

23.
Retaliation – The Reality
• The mere perception of retaliation is enough to deter reporting of
misconduct
• Where trust is high and perceptions of management and peers are
more positive, retaliation is far less prevalent
• Zero tolerance = 8% of employees experience retaliation as
opposed to 38% where top management does not take a stand
against retaliatory behavior

24.
Retaliation – The Experience
• Retaliation is now the most common form of discrimination
alleged in the US topping both race and gender.
• 82% of whistleblowers experience harassment after
making allegations
• 60% were discharged from their jobs

25.
Retaliation Experience
Whistleblowers may experience:
– Blacklisted from future employers
– Face social ostracism from co-workers
– Undergo stressful psychological strain
– Forced to transfer jobs
– Legal Actions
– Dismissal
– Blocked Promotion

26.
Anti-Retaliation Policy
• Implement a zero tolerance retaliation policy
• Train all employees on the policy
• Effectively manage investigations
• Position whistleblowing as not disloyal but supporting it

27.
Anti-Retaliation Policy
• Clear statement that retaliation is prohibited
• Retaliatory behavior will result in disciplinary action up to and
including termination
• Examples of retaliatory behavior and conduct
• Description of complaint procedures – file report
• Statement that complaints will be taken seriously, promptly
investigated and resolved as appropriate
• Statement that complaints will be regarded as confidential to the
greatest extent possible.

28.
Anti-Retaliation Policy
• Apply policies consistently
• Do not ignore or isolate claimants
• Address & document performance issues immediately
• Carefully review discipline & termination decisions
• Ensure communication is reinforced

29.
Anti-Retaliation Support
Supervisors/Decision makers trained on the following:
– Policy prohibits retaliation
– Basic element of retaliation claims
– Concept of adverse action
– How to communicate and reinforce anti-retaliation
policy
– How to observe employee non-compliance

30.
Summary
• Any hotline and case management system is better than none
• Whistleblower hotlines and the policies that support them are
designed to create a culture of integrity, empower employees and
improve morale
• Anti-retaliation policies and procedures encourage use of hotlines
and reinforce management’s commitment to transparency and
accountability

31.
Questions?
Get in Touch:
Shannon Walker
WhistleBlower Security
www.whistleblowersecurity.com
604.921.6875
shannon@whistleblowersecurity.com
Questions about i-Sight?
Joe Gerard, j.gerard@i-sight.com