Hotlines were a significant innovation brought about by the Federal Sentencing Guidelines more than 10 years ago, but many in the compliance community now view them as limited in scope and effectiveness. In fact, all of the panelists at the session I moderated at Ethisphere’s 9th annual Global Ethic’s Summit agreed that hotlines, by themselves, are not enough.
Given these limitations, Kim Bixenstine, Chief Compliance Officer, University Hospitals, described her organization’s hotline “a fail-safe” mechanism. Each of the panelists described their efforts to go beyond their hotlines to increase misconduct reporting. In the experience of Larry Karr, Associate General Counsel, North America, Ingredion Inc., using face-to-face training sessions as much as possible is a good way to build relationships and create an opportunity for employees to raise sensitive issues. Laurie Gallagher, Senior Director and Chief Counsel, Compliance, Saudi Basic Industries Corp. (SABIC), said her company uses a “speak-up” icon on everyone’s desktop that links to an anonymous reporting channel.
Kim Bixenstine’s hospital system recently started publishing patient’s reviews of their doctors from office visits, both positive and negative. Although this embrace of transparency initially met resistance, physician ratings and patient satisfaction have greatly increased.
Panelists agreed that a critical aspect of responding to misconduct is communicating back to those raising issues, even if anonymously. By posting status updates and a final determination, as simple as validated or not validated, the talented and articulate CECOs on the panel built trust and encouraged employees to take responsible action when they see misconduct.