FIFTH PRINCIPLE

Establish and maintain an integrity help-line
Monitoring and responding to violations

Establishing and maintaining an integrity help-line, this gives employees a place to go to with questions about ethical conduct as well as a place to report ethical concerns. A help-line not only provides the company with the opportunity to help influence ethical behaviour in real time, but it also gives the compliance personnel and company leadership insights into high risk activities. It can also provide valuable leads on potential serious legal issues that may warrant further investigation or possible remedial measures, in order to protect the company from losses and legal proceedings.

Often, employees are intimidated by the prospect of reaching out internally to raise a concern, due to fear of retaliation or self-incrimination. Therefore, companies opt to establish anonymous or at least confidential help lines and establish a non-retaliation policy.

An integrity help-line is only as good as its level of use. Therefore, it is crucial that the relevant leadership introduces and promotes the line in a way that encourages its use.

Employees in companies where leaders speak about ethics and compliance are 12 times more likely to believe that they are encouraged to speak up about violations.

(Source: Global Business Ethics Survey, Building Companies Where Values and Ethical Conduct Matter, 2018, EIC)

Three factors which particularly increase the probability of compliance and integrity violations by employees:

1. Poor leadership, which does not provide a personal example of ethics, and which does not penalise employees for violations,
2. Focusing on results, while expressing no concerns over how they will be reached,
3. Important changes, such as lay-offs, leadership replacements and expansion to new markets
(Source: Global Business Ethics Survey, Interpersonal Misconduct in the Workplace, 2018, EIC)

(Source: Global Business Ethics Survey, Building Companies Where Values and Ethical Conduct Matter, 2018, EIC)

Recommended indicators for the fifth principle

Indicators proving that the principle is implemented in business operations:

  • A line for consultation and raising concerns (violations reporting) in the field of compliance and ethics is formally established and all employees, contractors and other third parties are informed about it where warranted. Leaders regularly and openly encourage employees to speak about violations and promote the benefits of the consultation purposes of the help -line.
  • The integrity help-line management, including the proper procedure and timeline for responding to reports, is determined, and responsibilities are assigned to proper persons.
  • The procedures and methods for protecting persons who report violations in good faith against retaliation are defined; this is communicated to employees and operationally assured.
  • A registry of reported violations is established, indicating the time, subjects (with confidentiality protection assured), description of the violation and response to the report, including an internal investigation and other subsequent activities.
  • The line for reporting violations is functioning and active. Employees and other stakeholders are actually using the integrity line by asking questions and reporting violations of compliance and integrity.

Indicators proving that the leadership is making progress in implementing the principle in the company’s business practices:

  • What is the leadership and management attendance rate for compliance and ethics training?
  • What is the employees’ attendance rate for the training?
  • What is the proportion of successfully completed employees’ training and of employees’ certification about completing and understanding the training?
  • Do all important contractors and contractors, which perform high-risk tasks attend compliance and integrity training before they sign a contract?
  • How many times had the company rejected a new employee or a contractor for integrity-related reasons?