Speak Up Procedures - Institute of Business Ethics

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2 SPEAK UP PROCEDURES PART 2 Communication is a vital aspect of the policy, ensuring that all employees are aware of the policy and know how to raise a concern, as well as fostering trust in the procedures. The policy may be disseminated company-wide within the organisation’s code of ethics, via intranet sites, by email direct to staff, and in training sessions. Posters, pens, mouse mats and other gimmicks can be used to notify staff of the contact details for raising concerns. This can reinforce the seriousness with which the company takes the issue. In the communication of the policy, employees should know what to report, who to talk to, what will happen and how they will be treated. For those involved in the management of cases, a more detailed handbook and additional training can be helpful. Piloting A draft policy may be piloted with employees to ensure that the terminology used makes clear when employees should Speak Up and gives them the confidence to do so. For example, callers to a Speak Up line could be described as ‘witnesses’ to reduce the ‘informant’ connotation. Employees can be encouraged to ‘seek advice and guidance’ about questionable situations, rather than ‘reporting misconduct’. Training An important opportunity for awareness raising of the Speak Up procedure is in training programmes; for example in induction training and in training on the organisation’s code of ethics. Question and answer formats involving ethical dilemmas which employees may encounter are an effective way of getting the message across (Box 4). These can be incorporated into the code of ethics, through the organisation’s intranet or other training sessions. Box 4: Q&A examples GlaxoSmithKline Employee Guide to Business Conduct (2004) Question: My manager has been asking my co-worker for a date and keeps commenting on her appearance. She has told me it makes her very uncomfortable, but she is afraid to say anything because he might get mad at her. It’s not really my problem. What should I do? Answer: We all need to stand behind GSK’s commitment to equal treatment and a harassment-free workplace. If you are not comfortable raising this issue with your manager, you should contact Human Resources, your Compliance Officer, or the GSK Integrity Helpline. 12
SPEAK UP PROCEDURES PART 2 2 Box 4: continued Borealis: It’s A Question of Ethics (2005) Question: I am worried about what appears to be a new working practice that has been introduced to save costs. The new working practice might have a significant negative environmental impact. I know increasing cost efficiency is essential but this may be a step too far. Answer: We are committed to reducing the environmental impact of our operations and no working practice must be introduced which can significantly increase environmental concerns. Please contact our HSE organisation. Our HSE organisation has the responsibility to investigate concerns and complaints covering the environment. It is essential that managers and HSE hear about your concerns – so please speak out. In addition, you can always call the QuestionLine. Communicating outcomes Another way of raising awareness is to make known the outcomes of investigated cases. This will also encourage confidence in the procedure. For instance, once an incident which was brought to management’s attention by an employee has been resolved, a case study could be written in generic terms and published in the in-house journal. This will reinforce the message of the company’s support and commitment to taking employee concerns seriously. A section in the Annual Report on how often Speak Up arrangements are used each year relative to employee headcount and the relative seriousness of the issues raised could be considered. This will inspire confidence in the Speak Up programme both internally and externally (see Box 5). Box 5: Samples of information about Speak Up arrangements in Annual Reports BG Group Corporate Responsibility Report 2005: Whistleblowing We have had a Whistleblowing policy in place since 2000. In July 2005, we publicised the whistleblowing hotline in our employee magazine, to raise employees’ awareness of how they could raise concerns. In 2005, we investigated seven cases in accordance with our Whistleblowing policy, relating to malpractice (one case), Health, Safety, Security and Environment (HSSE) (three cases) and employee concerns (three cases). We also investigated six allegations of fraud. One employment contract was terminated and two incidents were reported to the police for further 13
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