13.0 VOLUNTARY INITIATIVES BY COMPANIES
Companies can do a lot of things in this regard. As whistle blowing primarily helps in better and more efficient functioning of a company, it is in the best interests of the company that it encourages whistle blowing by setting up appropriate mechanisms.
According to a study performed by Price Waterhouse Coopers in 2011, every company can follow a basic five step model( given below) for encouraging effective whistle blowing from its employees.
1 Gaining top level commitment-
This is the first and the most important step in creating an efficient whistle blower policy. There should be a trickle-down effect and that is possible only if the top management of the company is wholly committed to implementing this policy.
This policy should not be incorporated just for the sake of implementing a policy. The top managers of the company should sincerely believe and be committed that this policy would encourage employees to speak up against crime, which in the long run would only prove beneficial to the company.
A research has found out that people prefer working in an organization that has moral and ethical values to one that is purely profit minded.
Further, the responsibility of the top level management does not end with initiating such a policy; but the ultimate responsibility of the operational functioning of the policy must also rest with them.
2. Developing a whistle blowing policy-
Once top level commitment has been achieved, we can move ahead and develop a strong whistle blower policy. While formulating this, we must keep in mind the risks associated( like fraud, environmental damage, corruption etc.) and try to mitigate them. The survey results indicate that 30 % of the companies had informed their employees about the policy through code of conduct and ethics manuals while 27 % of them had employed trainings and inductions.
! Access to whistle blower policy- This includes the methods and means by which this policy can be made available to the employees. This can include manual of ethics and values, code of conduct etc. Induction trainings too can be conducted.
! Charters with the whistle blower policy can be hung in every department.
! Who are the users? – The primary intended users are definitely the employees of the company. In addition, third parties like suppliers, lenders, distributors and customers too should be given access to the policy; as fraud can happen at any level in an organization. According to the survey, 57 % of the companies do not give access to external parties.
! Channel to report crime- A dedicated team( say probably a team from the HR department) can be set up for dealing with these types of complaints. Crimes can be reported through e-mails or personally face to face. Hot line numbers too can be dedicated for this cause. 13 % of the companies had a dedicated hotline number for reporting fraud; while 28 % of the companies say that their employees prefer e-mails. The employee should be free to use the channel he / she is comfortable with. It is more important to communicate to the employees that they must report crime and they can do it through any of the above mentioned channels.
! Protection to whistle blowers- From the point of view of the employees, this probably would be the most important part of the policy. Employees should feel safe and secure. Many studies have shown that the biggest reason why employees do not expose crime is because they fear retaliation and humiliation from their colleagues. The company should adopt a zero tolerance stance to victimization of whistle blowers. As we saw earlier, whistle blowers are many a time subjected to harassment, suspension, denial of promotion and sometimes even dismissal. 19 % of the participants cited perceived risks as one of the reasons for not reporting crime.
3. Designing reporting mechanisms-
This involves an effective system which allows employees to formally communicate their concern. This would be followed by investigation. It is also important to apprise the employee the results of the investigation. Feedback is highly important; and this instills confidence in the employee.
4. Embed the policy-
Whistle blowing must be viewed as a process rather than as an event. The culture of reporting crime must be embedded in the very work culture of the organization and instilled in every employee ' s mind. This objective can be achieved by conducting frequent training sessions. Informal meetings with the top management can also help in this regard. 54 % of the respondents said that whistle blowing helps in improving organizational transparency and employee morale.
5. Monitoring and evaluation-
Once a whistle blower policy has been developed, maintaining it is very important. The policy must periodically be reviewed for any possible loopholes or
92