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Memo to Managers
Talking to Your Team About Asking Questions and Reporting Misconduct
Virtually every organization’s code of conduct says employees have the responsibility to report misconduct and to ask for guidance when needed to avoid their own misconduct.
While likely in writing, you should reiterate the need to report issues and ask questions regularly and talk about them because they are important—your staff wants to hear about important matters directly from you.
To help you with this conversation, consider sharing with your team the bigger picture “why” and “how” of reporting—emphasizing that leveraging the tools you provides helps us all build a stronger, more ethical organization.
Why Should Your Team Members Raise Questions or Report Potential Issues?
- Reporting concerns and raising questions helps us protect our organization—and one another. Explain that speaking up about wrongdoing and seeking guidance before acting are both critical because these actions protect our organization’s and employees’ livelihoods. We’ve seen repeatedly in the news how bad conduct, unchecked, can damage an organization’s reputation and financial health and ultimately endanger employees’ jobs. Use the latest business scandal to underscore your point.
- Raising questions or issues helps us all make more ethical decisions: Talk about the topics in the code of conduct that are relevant to your employees’ roles. Give examples of the types of misconduct that can occur in these areas and typical questions that can arise about each topic. Then explain what they should do if they encounter such violations.
What Are the Nuts and Bolts of Reporting? How Does it Work?
- Emphasize that your team can choose the reporting method that is most comfortable for them : Explain the resources our organization makes available for receiving reports and answering questions. Employees most often want to talk to their supervisors as a first resource. But make it clear that they have the alternative to use the management chain or your helpline. Make sure to say you will not take it personally if they choose to use a resource other than you.
- Describe what to expect when a team member makes a report: Describe what happens after an employee reports wrongdoing. Say what you will do if an employee speaks up to you and when you will provide updates. Explain the ethics hotline/helpline. This resource is frequently not well-trusted because employees do not understand the process. Talk about confidentiality. Make sure you know the answers to questions, like: Can I report anonymously? Who takes the call or web report? Are calls audio recorded? Is the helpline available 24/7? How will I get updates on my case? Who conducts investigations? How will I be informed of the outcome?
- Reinforce your openness to hearing what you team has to say: Tell employees that you are available. Encourage them to ask questions if they are not sure what to do and to come to you with concerns of misconduct. Let them know you support them and want to help. Then live up to these commitments.
While this may seem to be a long list, don’t tackle it all in one conversation. In fact, the messages will stick better if delivered as a series of discussions. Consider devoting a few minutes routinely in staff meetings to focus on the importance of speaking up and upholding the code of conduct.
If you do your part, they are more likely to do theirs.
Questions of the Month
Q: When I ask my team why they hesitate to speak up about misconduct, they say they don’t want to throw a coworker under a bus over a minor issue. How should I respond to them?
Your team’s response suggests they believe extreme action will be taken for anything reported. Try explaining that every report does not automatically lead to major discipline. For example, accepting a gift from a vendor that violates your company policies about gift receiving may result only in a word from a manager to send it back or to share it with the department. Any allegation that warrants a full investigation may also result in relatively minor corrective action—a policy may get amended or training may occur. Assure your team that their reports will not be met with an extreme response. Corrective action will be calibrated to fit the severity of the misconduct. Major discipline is reserved for major wrongdoing.
Q: I think employees in my company don’t report wrongdoing because they fear retaliation. How can I convince my team that our company is committed to protecting them from retaliation?
First, talk with your team about your company’s non-retaliation policy—though typically a policy is not enough reassurance. Try asking your compliance department to share their stats on how many allegations of retaliation they received over the past year. Chances are the number will indicate that retaliation is seldom reported, which is true across industries. This likely indicates that fear of retaliation is much more common than actual retaliation.
Also, employees want to know that their company is serious about disciplining retaliators. If your compliance department is not already internally publicizing sanitized cases related to retaliation, ask them to start. Finally, tell your team that you are committed to addressing any retaliation that occurs. Check in periodically with anyone that you know raised a concern to make sure they are not experiencing any negative consequence and take prompt action if they are.
Developing a successful and up-to-date code is one of the most cost effective ways of communicating about your ethics and compliance standards and expectations. And, not only is the code itself a valuable communications tool, but—if done right—the process of updating and drafting a new code also has important benefits.
Using Compliance Communicator
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