Risk & Compliance Matters

Ethics & Compliance Hotline FAQs: Top 5 Questions from the Hotline Benchmark Webinar Answered

During our recent webinar, we provided an in-depth tour through the findings of our 2015 Ethics & Compliance Hotline Benchmark Report.

Webinar attendees asked a number of valuable questions on topics ranging from hotline best practices to questions about our data set and calculation methodologies. Below are five of the top audience questions answered.

1. What is the best practice target for case closure days?

We recommended targeting an average case closure time rate of 30 days. We recognize that some more complex cases will take longer, but overall, cases should be closed in an average of 30 days. This will ensure that employees feel confident that their reports are being taken seriously.

2. What is the best practice for closing a case when an anonymous reporter does not provide additional information to investigate the case? Do you keep it as “in process” or enter in the attempts in the case notes and ultimately close out the case?

We recommend investigating the case to the fullest extent. If questions have been posed to the original reporter, allow four weeks for the anonymous reporter to follow-up. If the reporter does not follow up, note the attempts in the case and close the case. If the reporter follows-up at a later time, the case may be re-opened to continue the investigation. This underscores the need to make sure potential anonymous reporters are educated about the critical need for them to follow up on their reports to respond to requests for information from investigators.

3. With regard to HR issues that are reported to the HR department: do you suggest recording all of these reports? Some of these are minor HR issues handled by HR at the time of the report. How do we differentiate between these reports and more significant reports?

A. We recommend including all cases that are received, regardless of severity, within one case management system. This allows for better internal benchmarking and trend-spotting, as well as improved recordkeeping and better organization of cases.

4. Can you advise on best practices for closing cases in the case management system? Do you advise that only attorneys officially close out cases, or can the investigator close them out as well?

We recommend that cases be closed out after an investigator has completed their investigation and appropriate action has been taken—including notification to the reporter. We recommend that the senior person responsible for oversight of case management be ultimately responsible for determining when a case is closed.

5. What is your recommendation on how much information should be shared with a reporter concerning report outcomes?

We recommend sharing basic information with the reporter. At a minimum, it is important to advise that their report has been investigated and that appropriate action has been taken. Further, the reporter should be thanked again for raising the concern. If you believe it may make sense to share additional details in a particular case, be sure to consult with your legal team first for guidance.

Do you have additional questions on hotline best practices? Comment on this post and we’ll address them here—or feel free to contact us at any time.

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