Fixing a Whistleblower Programme to improve Compliance
The client is a multinational mining company operating in over 100 countries and listed on a major stock exchange.
The company has had a whistleblower programme for many years; however, the programme had never been reviewed or assessed and questions were being asked about whether it was truly effective. There were questions regarding:
- the quality of the hotline service provider, the tracking and the programme
- why reports were not followed up correctly or timely
- what trends could be drawn from the data and what steps needed to be taken to improve the programme
- whether the staff globally knew how to use the system and whether it worked in every country
- whether data was being collected from all sources or just the hotline
We worked with the client to conduct a review of the entire whistleblower programme. This involved looking at all aspects of the programme: policies, standard operating procedures, guidelines, investigation protocols, reporting structures, case management, call handling, non-retaliation practices and, of course, awareness.
In many engagements of this type, companies lack all of the above programme aspects and simply have a basic hotline from a hotline company and no other supporting systems, tools or processes to guide the programme. It should be noted here that the company did have all of the necessary documents, though some were in draft, some had been implemented, and some had been implemented but not followed.
We also held some small sessions in key markets to get the opinions of the local staff regarding the whistleblower programme. They were not training sessions, although there was an element of awareness or training. They were designed to:
- introduce the whistleblower compliance programme to many people for the first time and explain why the programme was important
- obtain feedback on the programme in that market
- understand what local issues in the market existed in terms of whistleblowing (e.g. whether it was culturally acceptable)
- gain a sense of trust from the employees in the whistleblower system’s confidentiality and non-retaliation.
HOW LONG DID IT TAKE?
About one month in total with visits to several operating entities and mining sites across several continents.
WHY THE RED FLAG GROUP?
- Solutions Oriented. The last thing the client wanted was for us to document all of the problems. They wanted root causes and fixes. They didn't simply want a deliverable telling them what they already knew.
- Fixed Pricing. We charged a set price for the project. This included all of our International travel. Our invoice reflected our price and did not change for any discrepancies.
- Global Delivery. We had to deliver this project in multiple countries. We had to engage in Africa, Asia and Europe. We had to have a project leader that had global delivery experience and the ability to travel on short notice.
- Content Knowledge. We know our stuff. We know the reasons why the programs don't work. We know the questions to ask and we k now the cause of many issues that appear in these programs.
- Designing the review of the whistleblower programme and how it was implemented
- Reviewing all material, communications, process and systems
- Conducting interviews and small group sessions in some countries to gain the Voice of the Customer
- Benchmarking against industry peers and where the gaps lay in the program
- Drafting a report for management and participate in several meetings
- Drafting a gap analysis and areas for improvement with clear steps for improvement