How to build and sustain trust in your speak-up program
Speak-up programs are common. Trust is built through follow-through. Webinar polling and audience discussion reveal what retaliation risk signals to senior leaders today.
Speak-up programs test trust after the report is made
Most organizations today can point to a speak-up program. Policies exist. Reporting channels are in place. Training has been delivered. On paper, the fundamentals appear sound.
But during a recent NAVEX webinar on top risk and compliance trends, audience polling and discussion pointed to a more difficult and consequential question: not whether employees can report concerns, but whether they believe it is safe and worthwhile to do so.
That distinction matters. For leaders accountable for culture, credibility, and regulatory exposure, trust is not established at intake. It is tested in what happens next.
Strong foundations, uneven follow-through
Webinar polling reflected broad awareness of retaliation risk, at least at a foundational level. Among 778 respondents, 88% said their organization has a formal non-retaliation policy in place. More than half, 56%, reported providing training to help employees and managers identify and report retaliation.
Beyond those first-line controls, the data showed a steady drop-off.
Only 41% of respondents said compliance is consistently involved when retaliation allegations arise, even when investigations sit outside the compliance function. Just 26% said retaliation allegations are reported separately to executive leadership or the board. Fewer than one in four indicated that they actively monitor for retaliation risk after a case has been closed.
Taken together, the polling offers a clear snapshot of how organizations are approaching retaliation risk today. Policies and training are widespread. Sustained oversight, visibility, and post-case follow-through are far less consistent.
The data does not speak to intent or outcomes. They do, however, surface a familiar pattern: organizations invest heavily in enabling speak-up, but far fewer have mechanisms in place to ensure accountability over time.
What practitioners are worried about – and what it signals to leadership
Audience questions and chat discussion added important context to the polling data.
Several participants raised concerns about anonymous reporting, questioning whether high rates of anonymity reflect employee preferences or underlying fear. Others asked how to distinguish low-risk complaints from early warning signs, and how to ensure that smaller issues are not dismissed in ways that quietly discourage future reporting.
Across those questions, one theme repeated consistently: how concerns are handled after they are raised matters as much as the hotline’s existence.
For leadership teams, those signals are difficult to ignore. Declining trust rarely announces itself directly. It shows up in hesitation, silence, or changes in reporting behavior over time.
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Retaliation risk is a governance issue, not an HR issue
During the discussion, Rebecca Walker, partner at Kaplan and Walker, emphasized that retaliation risk should be viewed through a governance lens.
Retaliation allegations are not simply employment matters. They raise questions about oversight, accountability, and whether organizational values hold under pressure. They also carry real regulatory consequences, particularly as enforcement agencies continue to scrutinize retaliation claims and reporting program effectiveness.
When boards receive only aggregate hotline metrics, without specific insight into retaliation trends or follow-through, they lose visibility into one of the most consequential risk signals a speak-up program can provide.
Benchmarking trust, not just activity
More mature organizations increasingly use whistleblowing and hotline benchmarks to challenge assumptions about program effectiveness.
Without context, metrics can mislead. With context, they become tools for better judgment. Benchmarking helps leaders understand not just how often concerns are raised, but how consistently they are investigated, escalated, and monitored over time.
Trust is not measured by the presence of a policy. It is reflected in patterns, follow-up, and outcomes.
The leadership question behind speak-up
For senior leaders, the question is not whether a speak-up program exists.
It is whether the organization can demonstrate that concerns are taken seriously, handled consistently, and followed through over time. It is whether leaders could explain their approach to retaliation risk to the board today – and defend it if regulators asked tomorrow.
That is where speak-up programs either reinforce trust or quietly erode it.
This article is part of our 2026 Top 10 Risk & Compliance Trends eBook. Check out the full eBook for more expert predictions for the year ahead.
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