Speak Up Procedures - Institute of Business Ethics

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2 SPEAK UP PROCEDURES PART 2 Box 5: continued investigation. We found evidence of fraud in one case and took remedial action. We found no evidence of fraud in the remaining two cases. None of these 13 cases was material or related to the Group’s financial reporting. GSK Corporate Responsibility Report 2005 Addressing misconduct Our Corporate Ethics and Compliance department monitors and tracks allegations and suspected cases of legal, ethical or policy infractions. It also ensures that all such allegations are appropriately investigated. Disciplinary action, up to and including dismissal, is taken where necessary. In 2005: • 1,126 employees were disciplined for misconduct (compared with 954 in 2004). • Of these, 331 were dismissed or agreed to leave the company voluntarily, compared with 256 in 2004. • Other disciplinary actions included verbal and written warnings (795 instances) and financial penalties. Employees staying with the company received retraining and increased monitoring. The numbers have increased since 2004. We believe this is probably due to better reporting of breaches, as people become more familiar with what should be reported and when. It is anticipated that the numbers may continue to increase during 2006, as detection and reporting mechanisms are further refined. The 1,126 disciplinary actions included 278 cases of employees breaching sales and marketing codes. These 278 cases resulted in 91 dismissals or separations from the company. There were also 100 verbal warnings and 87 written warnings. These included many small overspends on the allowed limits for hospitality during scientific meetings. 2.3 Dealing with local jurisdictions Different cultures may view Speak Up differently. See Box 6 for some historical contexts. In order to ensure that the Speak Up policy is effective in all countries in which the organisation operates, senior managers in international operations should be asked to participate in the development of the policy and procedures. They will be aware of any local cultural or religious sensitivities that may make it difficult for individuals to raise concerns. Consultation with employee representative bodies (e.g. trade unions or work councils), or a focus group of employees will also help ensure support for this policy. 14
SPEAK UP PROCEDURES PART 2 2 Box 6: Cultural differences For some countries, historical events or cultural norms have created a bias against Speaking Up: • In China, attempts to introduce corporate hotlines can remind employees of the horrors of the Cultural Revolution when citizens were encouraged to report ‘illegal activities’ to authorities, which included children reporting against parents, students against teachers, and neighbours against neighbours. • In Germany, encouraging anonymous or confidential reporting can bring to mind Gestapo tactics from World War II or the far-reaching informant networks of the Stasi in the former East Germany. • In South Africa, whistleblowers are associated with apartheid-era informants, called impimpis, who often faced public death if caught or suspected of reporting. • In Italy the nearest term for a whistleblower is ‘the repented’; this word is mostly used to describe someone breaking from and informing against the Mafia, often for reward or some personal interest. • In France, the term evokes images of the Vichy regime’s collaboration with the Nazis in World War II which perhaps underlies why CNIL, the French data protection authority, is vehemently against anonymous reporting. In some countries divided loyalties represent a significant challenge. • In Korea, a subordinate’s loyalty to a superior can be greater than his or her loyalty to the company. • In Japan, a tradition of lifetime employment and a strict seniority system can discourage workers from questioning management decisions, dictating that employees show unbounded loyalty to their co-workers. Source: ‘A Global Perspective on Whistleblowing’ International Business Ethics Review, Volume 7, Issue 2 Information about Speak Up procedures needs to be tailored to the culture in which the organisation operates, clarifying corporate standards with explanations that local employees will appreciate. Training can also include locally relevant examples on issues raised at manager level or by using the Speak Up line. 15
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