Hotline complaints can often concern workplace perceptions, not just apparent policy violations. Relying on hotline statistics can provide only a small slice, and at times a misleading analysis, of the state of the company’s compliance and ethics program. Consolidated reports to executive leadership and the board that include all policy violations, whether in HR, safety and health, IT, security and other areas outside compliance provide a more comprehensive and meaningful picture of emerging risks and problems. Best practices require company management to gather as much relevant data to evaluate risks, measure effectively in the aggregate, and keep problems from metastasizing. Committing to an “open reporting” culture can identify problems and program gaps before exposing the company to greater risk. How can compliance teams best shift the focus and lead this effort? How does middle management play a key role? How are companies advancing the culture now so that both executive management is better informed?
- Marsha Ershaghi Hames, Practice Leader in Education and Engagement in Governance, Culture and Risk Management, LRN
- David Stuart, Partner, Litigation, Cravath, Swaine & Moore LLP
- Allan Tananbaum, Vice President, Compliance & Deputy General Counsel, Ingersoll Rand
- Tom Tropp, Corporate Vice President, Ethics and Sustainability, Arthur J. Gallagher & Co.