The more things change, the more things stay the same. As compliance matures as an industry, we sometimes forget the foundational best-practices that our programs are built upon. Every last Friday of the month, we revisit some of our most educational posts from the past. We think you’ll find they are just as relevant today.
Originally published July 2016
For many years, I’ve been concerned that the term whistleblower—which admittedly has become engrained in both the public and private sectors—will have a discouraging and detrimental effect on some individuals who are considering reporting potential wrongdoing.
While many companies refer to their hotline as “ethics helpline” or “integrity helpline” to convey a more welcoming tone for employees, many executives refer to their employee reporters as “whistleblowers” sending a mixed message on the value of the report and the reporter.
And outside the United States, some believe that calling the reporting system a “whistleblower hotline” is a United States government regulatory requirement. This was pointed out to me during a recent presentation I gave in the United Kingdom, where a company official said, “The reason we call it a “whistleblower line” is because your regulators in the United States made it mandatory.”
Using a more neutral term like “reporter” might be difficult when dealing with reporting to government or regulatory agencies, many of whom use the term whistleblower in codified materials. And I can accept the use of the term when an employee reports a concern outside the organization.
However, internally, organizations can choose how they use—or don’t use—the term in internal materials and resources and that choice will impact employee comfort and confidence with the internal reporting mechanisms.
A More Neutral Term Like "Reporter" May Mean More Employees Feel Comfortable Meeting Their Obligations
All of our Codes of Conduct or mandatory training tell employees that they have an obligation to raise issues or concerns about any suspected or known misconduct.
So why do we stick a derogatory and intimidating label on an employee who is just doing what we ask and train them to do? It sounds like we don’t really mean it and we would rather that they don’t speak up at all.
For some organizations, perhaps that is intended. But for those organizations that have invested significant resources in building an effective ethics and compliance program, it is a clear and respectful choice to make.
I encourage organizations to consider carefully whether their employees would respond better to the term “reporter” in both formal and informal communications. The word “whistleblower” can not only have intimidating connotations, it may cause a potential reporter to keep an issue to themselves or take it directly to a regulator without giving the company an opportunity to address the issue internally.
After all, what we want to do is to make sure we are encouraging employees to report any and all concerns—not only those that rise to the level of “whistleblowing”—so that we can create a culture of integrity and protect our organizations from financial, reputational and legal risk.
Creating more transparent and ethical organizations where employee reporters feel comfortable sharing their concerns without fear of retaliation is something we can all celebrate.
Download our 2019 Ethics & Compliance Hotline Benchmark Report, for more data on internal whistleblower hotlines and incident management systems..