Friday, September 9, 2016

Ready to Implement an Internal Company Hotline?

As some point during a company's growth, leadership will need to develop a hotline - a mechanism for employees to report violations of laws and regulations, harassment, fraud, waste, and abuse. For Government contractors, that point comes, at the latest, when they receive a $5.5 million dollar contract that exceeds 120 days (see FAR 3.1004 and FAR 52.203-13). The pertinent regulations requires contractors to implement an internal control system that includes ...
An internal reporting mechanism, such as a hotline, which allows for anonymity or confidentiality, by which employees may report suspected instances of improper conduct, and instructions that encourage employees to make such reports.
There are many ways to set up an internal reporting mechanism. Most larger contractors have dual mechanisms that include a traditional 1-800 telephone number and a web-based complaint form. Some even offer face-to-face reporting.

In setting up a hotline, there are some considerations that need to be adhered to and basic questions that need to be answered if a contractor is going to be able to effectively pursue the alleged impropriety. First, contractors need to be serious about pursuing hot line allegations. Employees will know real soon whether a hotline is real or for show. Second, contractors need to ensure anonymity for anyone using the hotline. Third, bedside manner is critically important. Don't put Hannibal Lecter in charge of taking information over your hotline. Find someone that can show a little empathy for the relator. Fourth, make certain that the 1-800 number is answered. Asking someone to leave a message is not going to ensure anonymity. Fifth, provide feedback to the relator where you can. If a caller chooses to remain anonymous, there is no feedback expectation. Otherwise, provide feedback to the caller at the conclusion of your investigation. Finally, assign the responsibility for the investigation to someone in your organization savvy enough to understand the issues and is not a party to the issue or in the relater's chain of command.

As far as questions are concerned, the more information you can obtain or glean from a caller, the better, quicker, more effective your investigation will proceed. One of the Government's Inspector General's hotline questionnaires contains the following questions:

  • When did the issue occur?
  • Where did the issue occur?
  • Who took the action(s) at issue?
  • What did the person (or people) do?
  • To whom did the action(s) happen?
  • What law, regulation or policy was violated?
  • What remedy is being sought?
  • Names and positions of witnesses.
Employees who report to internal hotlines have other avenues to report their concerns - most notably the Hotlines operated by the Inspector General's of the various executive agencies. If they're not satisfied with or afraid to use your internal hotline and choose to use an outside hotline, there's no telling where an investigation will lead or how much extra time and effort you will expend in coordinating with outside parties.

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