Speak Up Procedures - Institute of Business Ethics

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4 SPEAK UP PROCEDURES Part 4 Operating the Policy 4.1 Resourcing Management commitment to the policy is the main resource required to demonstrate to employees that they are encouraged to raise concerns, that support will be given and that they will be respected and taken seriously. Other issues such as the cost of introducing an external helpline/hotline provider will vary according to the number of employees onsite (usually the pricing structure relates to size of organisation). Other costs include printing and dissemination of the policy and training of all staff, as well as designated internal contacts and those who will administer the process. It is important to budget for the maintenance and review of the scheme as employees will need to be reminded regularly of the policy and the support available. More guidance on reviewing the policy and procedure is outlined below. 4.2 Handling and logging a report It is important that employees feel able to raise concerns without fear of retaliation and that they are confident that their report will be kept confidential. This assurance should be given throughout the reporting and handling process. Reports to managers The first port of call when raising a concern is ideally a line manager. Training of managers in how to deal with staff concerns about ethical standards will ensure that concerns are handled in a consistent way throughout the organisation, (Box 12). Box 12: Guidance for managers on dealing with employees’ ethical issues • What are the facts of the situation? Are they clear? • Who is [which stakeholders are] affected by the situation and how? • What does the code of ethics say about the issue? • Who should have input to, or be involved in, resolving this issue? • What are alternative courses of action? Try to think of a ‘creative’ solution. • Consider a worst-case scenario for your preferred alternative to see how it affects the stakeholders. Rethink and revise your preferred alternative if necessary • Communicate and implement the decision quickly • What can you do to prevent the situation from re-occurring? 26
SPEAK UP PROCEDURES PART 4 4 If the concern is of a more serious nature, reporting can flow upwards through a choice of contacts, e.g. through line-management, to one or other appropriate functions in the organisation (e.g. legal department, HR, audit), to a dedicated company official or to an external ombudsman. Contact can be made directly or via help lines, and details for these should be communicated in the policy (see Part 3). Reports to Speak Up lines For efficacy and consistency a protocol for receiving calls should be established. One objective would be to ascertain the seriousness of the report. The following sample questions may help: (An illustrative call line procedure is in Appendix 2) • What is the concern? • Who is involved and how and why? • Where is this happening? – Is it widespread, or just at your location? • When did this start or happen (date & time)? How frequently is this happening? Is this still ongoing? Is it happening within working hours? • Why is this happening? – What has caused this? What are the consequences of this? • What is the scale of the damage or loss? • How do you know this has happened? Have you seen it directly yourself or has someone else told you? • Does anyone else know about this? Are you able to tell me who they are? (Reassure the caller that they will not be in trouble for not saying anything, but it might help the organisation to gather evidence). A confidential audit trail of conversations/emails with callers and responses to them as well as the details of any internal investigation must be kept. This is particularly important if a legal case may arise from the call. This could be in a central database held internally within the HR department or the department where responsibility for the Speak Up line is held. All calls should be logged and the facts of cases archived in line with the organisation’s practice. It is important to let the employee know what they can expect in terms of time frames for investigations, call backs, and progress reports. Examples of assurances given to those who report a concern could be: • A written summary of your call will be sent to the appropriate company personnel to investigate the concern raised • Feedback will be given to you • We undertake to investigate all concerns promptly and as confidentially as possible • We undertake to take all necessary actions to improve behaviours. 27
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Speak Up Procedures - Institute of Business Ethics

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