I’ve been worrying about whistleblowing lately. In particular, whether the traditional methods of reporting really are effective, as the level of reporting in many organisations just seems low. I’m not sure that this is a situation where “least said is soonest mended”, as the saying goes. If there’s misconduct occurring in an organisation, the compliance team needs to know, and know fast.
Risks and reporting behaviours
We understand that wrongdoing is more likely to occur in some locations and business operations than others. Arguably, these are the locations where it is most important to make reporting concerns as simple and straightforward as possible. But, in reality, how easy is this to practically achieve?
Thinking about risk profile vs ease of reporting, I did an analysis looking at the bottom third of countries in Transparency International’s Corruption Perception Index, cross referencing to the official language of the country and their main industries. What struck me was:
- The prevalence of high-risk industries (all the extractive industries, construction and tobacco) in these high-risk locations.
- The language profile of these countries.
While the “official” language in these countries may be English, French, Spanish or Portuguese, reflecting their colonial history, these are often multi-lingual societies where only a very small proportion of the population actually speaks the official language. There are a lot of other languages in the list too, including Azerbaijani, Ukrainian, Russian, Lao and Bengali. In total I found 28 different official languages in TI’s 60 most corrupt countries.
When implementing or reviewing a whistleblowing provider, consider whether they adequately manage the language variances in any relevant high-risk multilingual society.
The problem with phone calls
Many organisations’ reporting systems are still focused primarily on telephone-based hotlines, relying on someone making a conventional phone call to a call centre.
The historic model is that someone dials a toll-free number and speaks to a call centre operative who can only speak to them in one of a limited number of languages. If the preferred language of the caller is not available immediately, then there is usually a process for engaging an interpreter to facilitate a three-way conversation about the caller’s concerns.
This just does not feel like a simple or straightforward process likely to encourage an apprehensive whistleblower to persevere and I’m not surprised that there’s been a noticeable and sustained decline in phone-based reporting over the past few years. It seems to me that, if alternative methods were easily available, people would choose them.
Another interesting piece of research that I came across shows that penetration rates for mobile subscriptions in developing nations hit 98.7% at the end of 2017. On the surface this might be seen as a positive for hotline calling, but in my experience, many of the supposedly toll free numbers are not, in fact, toll free when called from a mobile.
However, the global uptake of mobile subscriptions has led to a rapid growth in the use of mobile apps in developing nations, which is a great opportunity for a more innovative approach to reporting concerns. Coupled with advances in voice recording and machine translation, the prevalence of mobile technology offers a genuine opportunity to rethink our approach to whistleblowing hotlines.
In your implementation or review, query whether your whistleblowing provider offers alternative reporting methods (or has these in their imminent pipeline).
Time for a change?
There are lots reasons that employees don’t report concerns. Some are cultural and are connected with fear of retaliation, confidentiality, local cultural norms relating to hierarchy and obedience. But some are technical and linguistic.
If we are interested in doing more than simply ticking the box to say we have a whistleblowing solution in place, then we need to make it easy for employees to report concerns, especially in the riskiest parts of our business. That means taking advantage of the technology they have and enabling them to say what they want quickly, easily and in their own language.
Waypoint GRC provides assistance with implementation or review of whistleblowing solutions. We welcome feedback on the issues raised in this blog and can be contacted at info@waypointgrc.com.
