Speak Up Procedures - Institute of Business Ethics

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4 SPEAK UP PROCEDURES PART 4 • Are there issues or incidents which have otherwise come to the board’s attention which they would have expected to have been raised earlier under the company’s Speak Up procedures? • Where appropriate, has the internal audit function performed any work that provides additional assurance on the effectiveness of the Speak Up procedures? • Are there adequate procedures to track the actions taken in relation to concerns made and to ensure appropriate follow-up action has been taken to investigate and, if necessary, resolve problems which have been highlighted by calls? • Are there adequate procedures for retaining evidence in relation to each concern? • Have confidentiality issues been handled effectively? • Is there evidence of timely and constructive feedback? • Have any events come to the committee’s or the board’s attention that might indicate that a staff member has not been fairly treated as a result of their raising concerns? • Is a review of staff awareness of the procedures needed? What does success look like? Effectiveness of this sort of policy is difficult to measure. According to IBE figures regarding use of Speak Up lines, the range in the number of calls per year is between 0.5% and 1% of the total workforce. The number of these calls which are ‘serious’ is very low. However, number of calls is not an effective measurement of success: just one call can make a difference to a company’s reputation. Low numbers may be an indication of suppressed concerns, or that there is an open culture where people are reporting their concerns to their managers. Higher numbers may also demonstrate openness and trust or can indicate that the scheme is being abused. Different countries might expect differing response levels, depending on general levels of corruption. The Transparency International Corruption Index can be a useful guide to this. 21 External hotline companies with the experience of similar sized organisations in a similar sector can provide an indication of effectiveness. GSK’s experience is set out in Box 13. 21 http://www.icgg.org/corruption.cpi_2006.html 30
SPEAK UP PROCEDURES PART 4 4 Box 13: Speak Up at GlaxoSmithKline Employees are encouraged to seek help and to report any concerns or suspected cases of misconduct. They can do this through their line management, a compliance officer, or through our confidential Integrity Helplines or offsite post office box (in the US). The Helplines and post office box are promoted through the Employee Guide to Business Conduct, on the GSK intranet and during training. The Corporate Ethics and Compliance function is promoted as a source of information and advice, as well as a mechanism for reporting concerns. In 2005 there were: • 3,644 contacts with the compliance functions, mainly in the US. This is an increase from 2,593 last year. • Of these, 77% were from employees seeking advice or information; 23% were from employees reporting suspected cases of misconduct. • Outside the US, mechanisms to track this information are evolving with general trends and issues being visible to senior management and addressed through action where necessary. GlaxoSmithKline Corporate Responsibility Report 2005 Among the ways of assessing the success of a Speak Up policy are: • Responses to a question in general employee surveys about the credibility and accessibility of the Speak Up line • Comments made in annual appraisals and exit interviews • Trends in call-line use by different businesses/departments and in different countries • Analysis of report outcomes • By making test calls to see if and how procedures are working. 31
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Speak Up Procedures - Institute of Business Ethics

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