Speak Up Procedures - Institute of Business Ethics

GOOD PRACTICE GUIDE
Speak Up Procedures
Published by The Institute of Business Ethics,
24 Greencoat Place, London SW1P 1BE

SPEAK UP PROCEDURES
The Institute of Business Ethics
The IBE was established in 1986 to encourage
high standards of business behaviour based on
ethical values.
Our vision
What we do
To lead the dissemination of knowledge and
good practice in business ethics.
We raise public awareness of the importance of
doing business ethically, and collaborate with
other UK and international organisations with
interests and expertise in business ethics.
We help organisations to strengthen their ethics
culture and encourage high standards of
business behaviour based on ethical values.
We assist in the development, implementation
and embedding of effective and relevant ethics
and corporate responsibility policies and
programmes.
We help organisations to provide guidance to
staff and build relationships of trust with their
principal stakeholders.
Institute of Business Ethics
24 Greencoat Place, London SW1P 1BE
Telephone: 020 7798 6040
Fax: 020 7798 6044
Website: www.ibe.org.uk
E-mail: info@ibe.org.uk
Registered Charity No. 1084014

SPEAK UP PROCEDURES
GOOD PRACTICE GUIDE
Speak Up Procedures
Edited by Katherine Bradshaw

SPEAK UP PROCEDURES
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IBE Good Practice Guide
Speak Up Procedures
ISBN 0 9549288 3 0
© IBE www.ibe.org.uk
First published March 2007
by the Institute of Business Ethics
24 Greencoat Place
London SW1P 1BE
A list of publications that have resulted from research, surveys, conferences,
and seminars is given at the back of this publication. The IBE’s website
(www.ibe.org.uk) is regularly updated and provides information on events and
other aspects of the Institute’s work.

SPEAK UP PROCEDURES
Contents
Page
Part 1: Why have a Speak Up Policy & Procedure? 2
1.1 Whistleblowing or Speaking Up? 2
1.2 Why have a Speak Up policy & procedure? 4
1.3 Summary of the regulatory background 6
Part 2: Making it Work: Context 10
2.1 Ethics policy and culture 10
2.2 Raising awareness 11
2.3 Dealing with local jurisdictions 14
Part 3: The Features of an Effective Speak Up Policy 16
3.1 Ownership of the Speak Up procedures 16
3.2 Scope of a Speak Up policy 16
3.3 Procedures 20
3.4 Internal or external Speak Up lines 21
3.5 Anonymity and confidentiality 22
3.6 Retaliation 23
3.7 Joint ventures, suppliers & family members 24
3.8 Policy format 24
Part 4: Operating the Policy 26
4.1 Resourcing 26
4.2 Handling and logging a report 26
4.3 Investigations 28
4.4 Escalating a local concern to head office 29
4.5 Monitoring 29
Appendix 1. Checklist for setting up an effective Speak Up policy 32
Appendix 2. Example of a call procedure 34
Appendix 3. Some titles of corporate Speak Up policies and ethics phone lines 39
Appendix 4. Some providers of external call lines 41
Appendix 5. Additional resources 42
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Part 1
Why have a Speak Up Policy & Procedure?
1.1 Whistleblowing or Speaking Up?
Whistleblowing usually refers to the process by which individuals raise concerns
at work. It originates from when a pit whistle was blown at times of an accident in
a mine; or it is analogous with a referee ‘blowing the whistle’ because of a foul in
a football match, or a policeman apprehending a criminal. In the Netherlands the
term used is ‘bell-ringing’; in Russia it is ‘lighthouse-keeping’. It implies letting
everyone know there is a problem. In recent years, the connotation of
whistleblowing has come to mean taking concerns outside the organisation,
usually by informing the media.
‘Blowing the whistle’ externally in this way is a last resort, occurring when
concerns have not been listened to or acted upon internally.
It is preferable for organisations that employees feel confident that their concerns
will be taken seriously and handled sensitively internally. Putting in place a
‘Speak Up’ or ‘speak out’ policy and procedure for its implementation provides a
mechanism for employees to raise concerns about anything they find unsafe,
unethical or unlawful. Institute of Business Ethics (IBE) research shows that a
quarter of employees are aware of misconduct at work but of that quarter, less
than half have actually reported it (Table 1). 1
Table 1
Did you report the misconduct?
all respondents who noticed a violation
Yes 48
Of which: Male 40
Female 60
No 52
%
The terms ‘whistleblowing’ or ‘Speaking Up’ are often used interchangeably and
can refer to the disclosure of a wide range of legal and ethical issues. The IBE
prefers the term ‘Speak Up’ as it has more positive and constructive connotations
for organisations wishing to encourage employees to raise their concerns without
fear of retaliation. It helps to foster an ‘open’ culture. Organisations can develop
the term which best fits their own ethical culture. Appendix 3 gives examples of
what some companies currently use. As well as employers, many professional
bodies also provide Speak Up lines for their members.
Any breach of a company’s code of ethics can be a reason to Speak Up (e.g.
conflicts of interest, sexual harassment, unfair treatment of staff etc). Whereas
1 S Webley & P Dryden (2005) Ethics at Work: a national survey, IBE
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Speaking Up concerns the welfare of others or of the organisation, companies
usually point out that any complaint an employee has regarding their own
personal circumstances should be dealt with according to a grievance policy. So
for example, someone witnessing a colleague being bullied would report it
according to the Speak Up procedure but someone who was being bullied
themselves would use the grievance procedure to address their concerns in the
first instance.
There have been high profile Speak Up cases reported in the media; so much so
that in the USA three whistleblowers were awarded Time Magazine’s ‘Person of
the Year’ award in 2002: Cynthia Cooper of Worldcom, Sherron Watkins of Enron
and Coleen Rowley of the FBI 2 (See Box 1 for details of well-known cases of
Speaking Up). Business Week declared 2002 ‘The Year of the Whistleblower’.
Regarding UK companies, whistleblowers recently revealed corrosion in BP’s
pipes in Alaska 3 and the mis-statement of leakage figures by Severn Trent. 4
Box 1: Well-known cases of Speaking Up
Although the following people are well known as whistleblowers, they had all
actually aired their concerns internally first.
Cynthia Cooper, the Vice President of Internal Audit at WorldCom, exposed the
massive accounting fraud at WorldCom in 2002. After conducting a thorough
investigation in secret, she informed WorldCom’s board that the company had
covered up $3.8 billion in losses through fraudulent bookkeeping. At the time,
this was the largest incident of accounting fraud in US history.
Sherron Watkins was a Vice President of the Enron Corporation. She wrote an
internal email message to Enron CEO Kenneth Lay concerning accounting
irregularities, warning him that Enron “might implode in a wave of accounting
scandals” – as it did in 2002.
Harry Templeton worked as a printer on the Scottish Daily Record and the
Sunday Mail, newspapers owned by Robert Maxwell’s Mirror Group. As a
trustee of the Mirror Group Pension Scheme, Templeton often found himself
alone in challenging Maxwell’s misuse of pension funds and this led to him
being fired in 1988. Only after Maxwell’s death a couple of years later was it
revealed that Maxwell had stolen £400 million of staff pension money. 5
2 For exposing the agency’s mishandling of information prior to the September 11, 2001 attacks
3 ‘Whistleblowers bring BP down to earth’, 9th August 2006, Financial Times
4 ‘More leaks but water profits soar by 30% at Severn Trent’, 7th June 2006, The Guardian
5 Watkins and Templeton, along with other whistleblowers, give an account of their experiences in RCalland and G Dehn (2004)
Whistleblowing around the world: law, culture and practice, ODAC/Public Concern at Work
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1.2 Why have a Speak Up Policy & Procedure?
The business case
Having a Speak Up procedure, which is run in an open and transparent manner, is
part of good business management for a number of reasons.
• Good risk management
If an issue is raised internally first, and acted upon, it is likely to reduce any
reputation damage. If employees contact their managers, rather than the
press or the regulator, about actual or suspected malpractice, the opportunity
arises to correct the problem before it escalates. Through helping to ensure
adherence to both the law and an organisation’s code of ethics, it can also
help to reduce an organisation’s legal claims.
• Maintain and improve performance
Speaking Up can be viewed as part of a strategy to maintain and improve
performance generally. By deterring malpractice and averting crises, a Speak
Up procedure can contribute to the efficient running of the organisation.
Reporting of issues will detect and possibly deter any further wrongdoings,
creating an open culture. It provides the senior management of an
organisation with the information they need to assist in decision-making and
control risk.
• Protect staff, customers and the public
An effective Speak Up policy and procedure can protect employees from health
and safety issues or bullying and harrassment from other members of staff.
Customers and the public can also be protected from the effects of
malpractice, for example, failure to comply with hygiene standards or falsifying
of test data.
• Reduce financial losses
Most organisations may have been or will be the victim of fraud or theft at the
hands of their own employees. The 8th Ernst & Young Global Fraud Survey 6
found that:
• 85% of the worst frauds against companies were committed by employees
• One in five employees stated that they were personally aware of people
stealing from their employers
• The rate of recovery of financial losses (from all sources) was just 51%.
• Improve staff morale and reduce staff turnover
A Speak Up policy sends a strong message to all levels of the workforce that
bad practice will not be tolerated. It reassures employees that their concerns
are important, and encourages problems to be brought to the attention of
management from within the company rather than through an external agent
such as the media. It makes for a happier workforce if staff believe and see
that mutual trust exists.
6 Fraud: the Unmanaged Risk 8th Global Fraud Survey (2003) Ernst & Young
http://www.ey.com/global/download.nsf/uk/Jan03_8th_Global_Fraud_Survey/$file/8th%20Global%20Survey.pdf
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• Increase investor confidence
A Speak Up procedure will help to improve investor confidence, by
demonstrating that the organisation is serious about good corporate
governance and has robust risk management measures in place.
• Lower insurance premiums
As management processes are assessed when insurers set premiums for
fidelity, and directors and officers’ liability insurance, having a Speak Up policy
in place, and disclosed to the company’s insurer, may lead to lower premiums.
Supporting employees
There are additional reasons why an organisation should consider the support it
offers employees.
Firstly, with developments in the internet and social networking sites, it is now
easier than ever for employees to make their concerns public. A recent example
of this is the case of Michael De Kort, a project manager for Lockheed Martin.
Having had his complaints ignored both internally and by government investigators
about what he saw as critical security flaws in a fleet of refurbished Coast Guard
patrol boats, he made a video and posted it on YouTube.com. 7
Secondly, there is often concern by employees that it would not be in their
interest to Speak Up. According to the IBE Ethics at Work survey, a quarter of
workers believe that reporting ethical concerns will result in them being branded
as troublemakers (see Table 2).
A working environment in which it is made clear that bullying, harassment and
discrimination are not tolerated will lead to fewer pay-outs at employment
tribunals. With staff morale and loyalty increased, retention rates are higher
and attracting potential recruits is easier. Fear of retaliation is exemplified in the
high profile cases of those who have spoken up. “You lose everything, your
career, your friendships, your social environment – everything is destroyed around
you,” says Dorte Schmidt-Brown, formerly of the European Commission, who blew
the whistle on accounting malpractice at her workplace. 8
Since the enactment of the Public Interest Disclosure Act (see below) there is
now more formal protection for those who report their concerns. One of the first
examples of a successful tribunal was that of Laurie Holden, who worked for the
train operator Connex. Following his reporting to the health and safety executive
that he feared more trains would pass signals at red, he claimed that Connex
embarked on a campaign to silence him and force him out. He was awarded
£55,000 for unfair dismissal. 9
7 ‘On YouTube, Charges of Security Flaws’ 29th August 2006 Washington Post www.washingtonpost.com/wp
dyn/content/article/2006/08/28/AR2006082801293.html
8 ‘To safeguard the interests of the institution' - but was action taken quickly enough?’ Financial Times 16 June 2003
9 ‘‘Whistle blower’ makes legal history’ 19 April, 2002 BBC http://news.bbc.co.uk/1/hi/england/1939926.stm
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Table 2
What was your reason for not blowing the whistle?
%
Felt it might jeopardise my job 13
It’s none of my business 19
Felt I might alienate myself from colleagues 21
It’s fair game 3
Everybody’s doing it 12
Other 23
Don’t know 9
1.3 Summary of the regulatory background
The Public Interest Disclosure Act (1998)
The Public Interest Disclosure Act (PIDA) came into force in the UK on 2nd July
1999. It was borne out of the enquiries into several major disasters (such as the
sinking of the Herald of Free Enterprise, the Clapham rail crash and the collapse
of BCCI). While the enquiries into these disasters focused on the adequacy of
laws and regulatory controls, they revealed that staff had been aware of the
danger but had not felt able to raise the matter internally or to pursue it when
their concern was not taken seriously.
The PIDA encourages people to raise concerns about malpractice in the workplace
by offering protection against victimisation if their concern is considered a
“qualifying disclosure”. The PIDA helps ensure that organisations respond by:
• addressing the message rather than the messenger; and
• resisting the temptation to cover up serious malpractice.
Through protecting whistleblowers from dismissal and victimisation in the
circumstances set out in Box 2, the Act is considered to promote the public
interest.
Combined Code on Corporate Governance
In July 2003, the UK Financial Reporting Council published the revised Combined
Code on Corporate Governance. It sets out standards of good practice in relation
to issues such as board composition and development, remuneration,
accountability and audit and relations with shareholders.
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Box 2: The PIDA definition of a “qualifying disclosure”
A “qualifying disclosure” means any disclosure of information which, in the
reasonable belief of the worker making the disclosure, tends to show one or
more of the following:
a) That a criminal offence has been committed, is being committed or is
likely to be committed
b) That a person has failed, is failing or is likely to fail to comply with any
legal obligation to which he is subject
c) That a miscarriage of justice has occurred, is occurring or is likely to
occur
d) That the health or safety of any individual has been, is being or is likely
to be endangered
e) That the environment has been, is being or is likely to be damaged, or
f) That information tending to show any matter falling within any one of the
preceding paragraphs has been, is being, or is likely to be deliberately
concealed.
The Act also covers incidents that occur outside the UK:
“It is immaterial whether the relevant failure occurred, occurs or would occur in
the United Kingdom or elsewhere, and whether the law applying to it is that of
the United Kingdom or of any other country or territory.”
Source: Public Interest Disclosure Act 1998 10
In June 2006, a new provision on Speaking Up was added to the Code:
The audit committee should review arrangements by which staff of the
company may, in confidence, raise concerns about possible improprieties in
matters of financial reporting or other matters. The audit committee's
objective should be to ensure that arrangements are in place for the
proportionate and independent investigation of such matters and for
appropriate follow-up action.
The Combined Code on Corporate Governance. Financial Reporting Council,
June 2006 11
Committee on Standards in Public Life
An important precursor to the PIDA was a report of the Committee on Standards
in Public Life. Following consultations with Public Concern at Work 12 , the UK’s
leading authority on public interest whistleblowing, it recommended that an
effective internal system for the raising of concerns should include:
10 http://www.opsi.gov.uk/acts/acts1998/80023--a.htm
11 http://www.frc.org.uk/corporate/combinedcode.cfm
12 See Appendix 5
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• A clear statement that malpractice is taken seriously in the organisation
and an indication of the sorts of matters regarded as malpractice
• Respect for the confidentiality of staff raising concerns if they wish, and
the opportunity to raise concerns outside the line management structure
• Penalties for making false and malicious allegations
• An indication of the proper way in which concerns may be raised outside
the organisation if necessary.
“[This approach…] goes further by inviting all staff to act responsibly to
uphold the reputation of their organisation and maintain public confidence. It
might help to avoid the cases when the first reaction of management faced
with unwelcome information has been to shoot the messenger.”
Whistleblowing Best Practice - Second Report, Committee on Standards in
Public Life, May 1996 13
Speak Up legislation in other countries
UK organisations operating overseas may be governed by legislation in other
countries. Some examples are below.
Sarbanes-Oxley Act 2002 (US)
In the wake of the Enron and Worldcom collapses, the Sarbanes-Oxley Act of
2002 was enacted in the US. It contains significant protections for corporate
whistleblowers. As part of the mandated audit committee function, publicly
traded corporations must establish procedures for employees to file internal
complaints and procedures which would protect the confidentiality of employees
who file allegations with the audit committee.
CNIL (France)
In May 2005, the French Data Protection Authority (Commission Nationale de
l'Informatique et des Libertés, or CNIL) refused to authorise two whistleblowing
programmes submitted by the multinational burger chain McDonald’s and by
CEAC, a division of Exide Technologies. The companies had prepared these
programmes in order to comply with the requirements of the Sarbanes-Oxley Act
of 2002. The grounds for refusal were twofold: that employees might be deprived
of certain rights to which they are entitled under French law, and that such
programmes are tantamount to systems of “professional incrimination” or
“professional denunciation” that could be slanderous.
These decisions have prevented multinationals from simultaneously complying
with Sarbanes-Oxley requirements and French data protection laws.
13 http://www.pcaw.co.uk/about/nolan.html
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In light of this conflict, in November 2005, CNIL adopted a set of eleven
recommendations that now permit companies to obtain its authorisation on a
case-by-case basis. The rights of individuals directly or indirectly incriminated
through them must be guaranteed with regard to personal data protection rules.
These include the right to such data being collected fairly; the right to be informed
that such data is being processed; the right to object to such processing for
legitimate reasons; the right to have any inaccurate, incomplete, ambiguous or
outdated information rectified or removed. 14
Germany
Under German law, employee-management councils must sign off on a wide range
of workplace conditions, from hiring and firing to the position of desks in an
office. German courts recently ruled against Walmart, deeming its hotline for
employees to report on colleagues' misconduct as violating German Law.
Walmart has since pulled out of Germany, and analysts cite its failure to
understand German culture and working practices as one of the reasons for its
failure. 15
As well as bearing in mind legislation in other countries when setting up a global
Speak Up procedure, it is important to consult with local staff and agencies.
Different cultural values may mean different attitudes to Speaking Up. This is
discussed in Part 2.
1
14 http://www.pcaw.co.uk/cnil/index.html
15 ‘Wal-Mart: Struggling In Germany’ 11 April 2005 Business Week
http://www.businessweek.com/magazine/content/05_15/b3928086_mz054.htm
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Making it Work: Context
2.1 Ethics policy and culture
A Speak Up policy will be more effective when it forms part of an established
ethics policy and programme. An ethics policy provides a framework for
employees’ decision making in line with the organisation’s stated ethical values.
It sets out the mechanisms the organisation has put in place to embed and
monitor those values. It also reassures staff that the organisation will take any
concerns they have seriously and will support them if they report unethical
behaviour. A Speak Up policy will detail this commitment further.
See Box 3 for some examples of how companies express this commitment to
staff:
Box 3: Commitments to staff
Cadbury Schweppes ‘Our Business Principles’ (2003)
Speaking up
If you know or have genuine suspicions of any legal violation in work-related
issues or breaches of these principles, you should report them to your
manager or human resources department so that we can take action. If your
concern is in relation to a legal violation or breach in which you believe both
your manager and the human resources department to be implicated you
should contact the chief legal officer at our group headquarters in London.
We will make confidential enquiries and make sure that we keep you informed
as appropriate. We will make all proper efforts to protect the confidentiality of
those who raise concerns. We will not criticise anyone for speaking up, or for
failure to speak up on earlier occasions. We will not permit retaliation for
reports of misconduct by others made in good faith by employees. We will
treat any attempt to prevent employees from raising concerns as a serious
disciplinary offence.
United Utilities ‘Business Principles’ (2003)
Compliance Disclosure
• We aim to create a working environment where employees feel able to bring
to the attention of the company, concerns about particular incidents of
wrongdoing, or other suspected malpractice, without fear of criticism or
future discrimination.
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Box 3: continued
• We will take no action against, nor will there be any threat to the career
prospects of, any employee or contractor who reports, in good faith, and
with genuine cause for concern that:
• a criminal office has been, is being, or is likely to be committed; or
• there has been, is, or is likely to be a failure to comply with legal
obligations; or
• a miscarriage of justice has, is or is likely to take place; or
• any established company policy including these business principles in
force from time to time is being flouted whether deliberately or otherwise.
• We undertake to treat details of individuals who report such matters with
the utmost confidence. That person’s identity will not be disclosed unless it
is absolutely necessary to do so in connection with the investigation of the
disclosure.
• We will not tolerate retaliation or victimisation of any employee of the
company because of such disclosure.
• Violation of these business principles may lead to disciplinary or criminal
action.
Resistance to change
An established ethics programme and culture of trust is essential for an effective
Speak Up policy. When establishing a Speak Up procedure, organisations may
face resistance from all ranks of employees. The implementation of a Speak Up
policy can imply a culture change which, although positive, may be seen as
threatening the status quo.
• Staff may feel cynical about a new initiative if there is little trust within the
organisation
• Middle managers can view those that Speak Up as a threat to their authority
• Top management often do not recognise the role of staff in guarding corporate
reputation and are the most susceptible to the ‘say-do’ gap, i.e. saying one
thing but doing another. They can be remote from the day to day operations
where many ethical dilemmas arise.
2.2 Raising awareness
Given these challenges, it is important that the policy and the reasons for it are
properly disseminated throughout the organisation, alongside a code of ethics
which will help guide staff in their assessments of what is the ‘right thing to do’
in their workplace.
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Communication is a vital aspect of the policy, ensuring that all employees are
aware of the policy and know how to raise a concern, as well as fostering trust in
the procedures. The policy may be disseminated company-wide within the
organisation’s code of ethics, via intranet sites, by email direct to staff, and in
training sessions. Posters, pens, mouse mats and other gimmicks can be used
to notify staff of the contact details for raising concerns. This can reinforce the
seriousness with which the company takes the issue. In the communication of
the policy, employees should know what to report, who to talk to, what will
happen and how they will be treated. For those involved in the management of
cases, a more detailed handbook and additional training can be helpful.
Piloting
A draft policy may be piloted with employees to ensure that the terminology used
makes clear when employees should Speak Up and gives them the confidence to
do so. For example, callers to a Speak Up line could be described as ‘witnesses’
to reduce the ‘informant’ connotation. Employees can be encouraged to ‘seek
advice and guidance’ about questionable situations, rather than ‘reporting
misconduct’.
Training
An important opportunity for awareness raising of the Speak Up procedure is in
training programmes; for example in induction training and in training on the
organisation’s code of ethics. Question and answer formats involving ethical
dilemmas which employees may encounter are an effective way of getting the
message across (Box 4). These can be incorporated into the code of ethics,
through the organisation’s intranet or other training sessions.
Box 4: Q&A examples
GlaxoSmithKline Employee Guide to Business Conduct (2004)
Question: My manager has been asking my co-worker for a date and keeps
commenting on her appearance.
She has told me it makes her very uncomfortable, but she is afraid to say
anything because he might get mad at her. It’s not really my problem. What
should I do?
Answer: We all need to stand behind GSK’s commitment to equal treatment
and a harassment-free workplace. If you are not comfortable raising this
issue with your manager, you should contact Human Resources, your
Compliance Officer, or the GSK Integrity Helpline.
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Box 4: continued
Borealis: It’s A Question of Ethics (2005)
Question: I am worried about what appears to be a new working practice that
has been introduced to save costs. The new working practice might have a
significant negative environmental impact. I know increasing cost efficiency is
essential but this may be a step too far.
Answer: We are committed to reducing the environmental impact of our
operations and no working practice must be introduced which can significantly
increase environmental concerns. Please contact our HSE organisation. Our
HSE organisation has the responsibility to investigate concerns and
complaints covering the environment. It is essential that managers and HSE
hear about your concerns – so please speak out. In addition, you can always
call the QuestionLine.
Communicating outcomes
Another way of raising awareness is to make known the outcomes of investigated
cases. This will also encourage confidence in the procedure. For instance, once
an incident which was brought to management’s attention by an employee has
been resolved, a case study could be written in generic terms and published in
the in-house journal. This will reinforce the message of the company’s support
and commitment to taking employee concerns seriously.
A section in the Annual Report on how often Speak Up arrangements are used
each year relative to employee headcount and the relative seriousness of the
issues raised could be considered. This will inspire confidence in the Speak Up
programme both internally and externally (see Box 5).
Box 5: Samples of information about Speak Up arrangements in
Annual Reports
BG Group Corporate Responsibility Report 2005:
Whistleblowing
We have had a Whistleblowing policy in place since 2000. In July 2005, we
publicised the whistleblowing hotline in our employee magazine, to raise
employees’ awareness of how they could raise concerns.
In 2005, we investigated seven cases in accordance with our Whistleblowing
policy, relating to malpractice (one case), Health, Safety, Security and
Environment (HSSE) (three cases) and employee concerns (three cases). We
also investigated six allegations of fraud. One employment contract was
terminated and two incidents were reported to the police for further
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Box 5: continued
investigation. We found evidence of fraud in one case and took remedial
action. We found no evidence of fraud in the remaining two cases. None of
these 13 cases was material or related to the Group’s financial reporting.
GSK Corporate Responsibility Report 2005
Addressing misconduct
Our Corporate Ethics and Compliance department monitors and tracks
allegations and suspected cases of legal, ethical or policy infractions. It also
ensures that all such allegations are appropriately investigated. Disciplinary
action, up to and including dismissal, is taken where necessary.
In 2005:
• 1,126 employees were disciplined for misconduct (compared with 954 in
2004).
• Of these, 331 were dismissed or agreed to leave the company voluntarily,
compared with 256 in 2004.
• Other disciplinary actions included verbal and written warnings (795
instances) and financial penalties. Employees staying with the company
received retraining and increased monitoring.
The numbers have increased since 2004. We believe this is probably due to
better reporting of breaches, as people become more familiar with what
should be reported and when. It is anticipated that the numbers may continue
to increase during 2006, as detection and reporting mechanisms are further
refined.
The 1,126 disciplinary actions included 278 cases of employees breaching
sales and marketing codes. These 278 cases resulted in 91 dismissals or
separations from the company. There were also 100 verbal warnings and 87
written warnings. These included many small overspends on the allowed
limits for hospitality during scientific meetings.
2.3 Dealing with local jurisdictions
Different cultures may view Speak Up differently. See Box 6 for some historical
contexts. In order to ensure that the Speak Up policy is effective in all countries
in which the organisation operates, senior managers in international operations
should be asked to participate in the development of the policy and procedures.
They will be aware of any local cultural or religious sensitivities that may make it
difficult for individuals to raise concerns. Consultation with employee
representative bodies (e.g. trade unions or work councils), or a focus group of
employees will also help ensure support for this policy.
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Box 6: Cultural differences
For some countries, historical events or cultural norms have created a bias
against Speaking Up:
• In China, attempts to introduce corporate hotlines can remind employees of
the horrors of the Cultural Revolution when citizens were encouraged to
report ‘illegal activities’ to authorities, which included children reporting
against parents, students against teachers, and neighbours against
neighbours.
• In Germany, encouraging anonymous or confidential reporting can bring to
mind Gestapo tactics from World War II or the far-reaching informant
networks of the Stasi in the former East Germany.
• In South Africa, whistleblowers are associated with apartheid-era
informants, called impimpis, who often faced public death if caught or
suspected of reporting.
• In Italy the nearest term for a whistleblower is ‘the repented’; this word is
mostly used to describe someone breaking from and informing against the
Mafia, often for reward or some personal interest.
• In France, the term evokes images of the Vichy regime’s collaboration with
the Nazis in World War II which perhaps underlies why CNIL, the French
data protection authority, is vehemently against anonymous reporting.
In some countries divided loyalties represent a significant challenge.
• In Korea, a subordinate’s loyalty to a superior can be greater than his or
her loyalty to the company.
• In Japan, a tradition of lifetime employment and a strict seniority system
can discourage workers from questioning management decisions, dictating
that employees show unbounded loyalty to their co-workers.
Source: ‘A Global Perspective on Whistleblowing’ International Business
Ethics Review, Volume 7, Issue 2
Information about Speak Up procedures needs to be tailored to the culture in
which the organisation operates, clarifying corporate standards with explanations
that local employees will appreciate.
Training can also include locally relevant examples on issues raised at manager
level or by using the Speak Up line.
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The Features of an Effective Speak Up Policy
A Speak Up policy may be a stand alone document or be positioned within an
organisation's code of ethics. The policy sets out an organisation's commitment
to supporting its employees to raise issues of concern to them and to report
suspected or observed misconduct. It may describe the reasons for the policy, the
mechanisms established and resources available for its implementation, and the
nature and degree of support that staff can expect.
Alternatively, a separate document, notice or other means of communication may
be used to inform staff of the procedures available to them for seeking guidance,
raising concerns or reporting ethical and legal malpractice.
Things to consider before setting up a Speak Up policy include: where
responsibility lies for its implementation; what issues and concerns are covered;
whether to use internal or external call lines; anonymity; and whether the
procedure covers joint ventures and families of staff. Dealing with local
jurisdictions and making the policy relevant to operations in other countries are
also worth consideration.
3.1 Ownership of the Speak Up procedure
An IBE survey of Speak Up policies of 50 FTSE 350 companies 16 found that the
functions most likely to have responsibility for the Speak Up process were:
• Global Compliance Director/Corporate Compliance Officer/compliance and
ethics function/Global Ethics panel
• Company Secretary
• Corporate Governance Officer
• Group General Counsel
• Internal Audit
• Human Resources
Some companies appoint local ‘ethics ambassadors’ in all locations who are
trained, among other things, to answer (or refer up) questions on ethics issues,
including those related to reporting of malpractice. For instance, they can offer
guidance on what to do if there appears to be a potential conflict of interest or if
someone suspects that an expense claim is being ‘enhanced’.
3.2 Scope of a Speak Up policy
A Speak Up policy needs to set out the types of issues which it covers or which
are excluded. Some organisations stipulate that an employee can seek advice or
raise any kind of issue that concerns them. Other organisations stipulate that a
16
16 Survey of 50 FTSE 350 companies whistleblowing policies, IBE, February 2006

SPEAK UP PROCEDURES
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Speak Up line is solely for employees to report issues which concern or involve
others such as breaches of the codes of ethics. (Issues which concern only the
employee may be taken up through grievance procedures).
3
Issues that might be raised using a Speak Up procedure include:
• Safety
• Conflicts of interest
• Bullying, harassment and discrimination of others
• Gifts and hospitality
• International business
• Copyright usage
• Unlicensed software
• Employment law
• Theft
• Bribery, facilitation payments
• Improper use of company assets
• Falsifying reports
• Workplace violence
• Drug or substance abuse
• Government contracts
• Environment
• Antitrust
• Insider trading
• Misuse of confidential information
• Supplier behaviour
Some companies recognise differences in Speak Up lines in other locations and
the different meanings implied by certain terms. For example:
A case in the US is deemed to be ‘whistleblowing’ when someone reports
misconduct that is not directly affecting them. For example, a female
employee reporting that she is being sexually harassed by a male supervisor
would not be considered as whistleblowing. However, a report by another
employee that a female employee is being harassed by a male supervisor
would be considered whistleblowing. All instances of whistleblowing are
identified and reported as such to the US Compliance and Ethics Committee
at their periodic meetings, and also to Group Legal.
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In the UK, any business conduct related allegation or request for advice is
recorded. We record ‘business conduct cases’ not ‘whistleblowing cases’.
IBE Benchmarking Survey 2006 respondent
Whatever the issues, individual employees make a judgement about what and
what not to raise. It is important therefore, that organisations give employees
some form of guidance as to what is the right way to do business and what the
company expects. Box 7 gives two examples.
Box 7: Guidance to employees
Reporting Concerns
Identifying A Business Conduct Issue
It is often difficult to recognise when a business conduct issue is happening,
especially at work where interaction with other employees, different
perspectives and business pressures can override awareness of some of the
risks associated with decisions.
Every employee is responsible for acting consistently with the Charter and
with the policies and standards described in this Guide. If you have any
doubts about the appropriateness of your behaviour ask yourself the following
questions before you act:
• Is my behaviour, or the decision I am about to make, in line with the BHP
Billiton Charter and values?
• Could my behaviour directly or indirectly cause injury or endanger anyone's
health? (In this case, do not take the action creating the risk.)
• Would my behaviour comply with all relevant laws and regulations?
• Would my behaviour violate any Company policies or standards?
• Would this behaviour make me feel uncomfortable or uneasy?
• Could I feel comfortable telling my work colleagues, family and friends
about my behaviour? and
• How would this behaviour appear to others if it was described in the
newspaper headlines or on the television news?
If you still have concerns discuss the situation with your manager, supervisor
or one of the other sources of advice listed in the Guide.
BHP Billiton Guide to Business Conduct 2004
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Box 7: continued
No one expects you to be your own expert on the application of specific laws
and regulations; rather, Diageo wants you to be aware of the issues raised
in this code, and to take the initiative to get advice and to report potential
violations of law and Diageo policies. You have many options, including the
SpeakUp Helpline, which accepts calls confidentially and anonymously.
There is to be no retaliation against any person for asking advice or making
a report. The important thing is this: SpeakUp! Protect yourself, protect the
business: ask questions, challenge; make an anonymous call if all else fails.
However, your most direct source of information and action is your manager.
Diageo Code of Business Conduct 2003
It is important to encourage employees to speak up as soon as possible, before
situations get out of hand. Box 8 gives an example of encouragement of early
reporting:
Box 8: Early reporting
What You Should Do If You Don’t Have All The Facts
If you have knowledge of or suspect any misconduct, call with the facts you
do have.
We do not necessarily expect you to have all the answers, but in general, the
more specific the information you can provide, the better. Please try to
include the specific concerns, when and where something occurred, who was
involved, whether there is an ongoing problem or a need for immediate
action, and any other information that could help the company get all the
information it needs. Let the company look into the matter to determine if
there is a reason for concern. Do not attempt to conduct an investigation
yourself.
GlaxoSmithKline Employee Guide to Business Conduct (2004)
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3.3 Procedures
Some companies encourage staff to raise concerns with their line manager in the
first instance so as to resolve issues locally. Others seek to decouple ethics from
line management so that staff feel able to address concerns to whoever they feel
most comfortable doing so.
Box 9 shows the framework used by National Grid regarding what procedures
staff may follow for guidance or raising different concerns and when they might
use their Business Advice Service.
Box 9: Business Conduct Advice Service Flowchart
You want to seek guidance about the Standards or report a concern about wrongdoing
Seek advice from your supervisor or manager
If you are not
comfortable
speaking to your
supervisor or manager
Guidance received
Report a wrongdoing or your
manager does it for you
Contact the Business Advice
Service to seek advice or
report a wrongdoing
You make an informed decision
Matter Closed
Guidance
You are provided guidance
and interpretation of policy.
(If necessary, subject
matter experts will be
consulted, e.g.,
inside counsel)
You make informed
decision
Report of Wrongdoing
You will be asked questions
intended to provide
sufficient information for
fact finding to take place.
Where appropriate an
investigation team will be
assigned, e.g., HR, Internal
Audit, Legal, etc., to conduct
an investigation to gather
and establish relevant facts.
If a wrongdoing has occurred
facts will be reported to
management. Management
will take appropriate action.
Business Advice Service
ensures actions are fair and
consistent and ensures that
lessons learned are applied
across National Grid.
Case concluded
with you
Source: National Grid’s UK Code of Business Conduct
Case Closed
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For staff who do not feel their concern has been addressed by their line manager
or who feel uncomfortable raising a particular issues with local staff, it is
common practice for organisations to make a dedicated telephone line, email
address or weblink available.
For some companies this will be a helpline (such as an ethics helpline) or web
page which can be used for enquiries about, for example, the ethics code or
about clarifying what is correct business practice, as well as for reporting
concerns about misconduct. This is considered useful for encouraging
constructive and open discussion around ethical issues and dilemmas.
For some companies, mechanisms for making enquires are separate from those for
reporting observed or suspected misconduct (by for example, having a dedicated
Speak Up - rather than enquiry - line).
Some organisations employ an ombudsperson as a further point of contact for
staff wishing to raise concerns but not wanting to notify their employer through
official channels. An employee who contacts an ombudsperson does not put the
company on notice. As neutrals, ombudspersons do not function as advocates for
the company or any individual, and they do not investigate issues. Rather, they
assist in the process of examining issues as they are raised, and they do so in
confidence 17 . The ombudspersons are available to help staff raise issues of
concern in guaranteed confidence or to explore options for how to address those
concerns themselves. The following describes the ombudsperson’s role at United
Technologies:
The ombudsperson serves as a confidential and informal information
resource, communications channel, complaint handler and dispute resolver,
and a person who helps an organization work for change. The ombudsperson
is also a designated neutral within our organization and, as such, is not an
advocate for any individual or point of view.
To safeguard both the appearance and practice of neutrality and
confidentiality, our ombudspersons do not keep case records and resist
appearing as a witness in judicial or quasi-judicial proceedings. UTC
ombudspersons do not represent or act formally on behalf of a manager, on
behalf of the employer, or of any employee.
Source: http://www.utc.com/responsibility/ombuds/resource.htm
3.4 Internal or external Speak Up lines
One of the practical decisions organisations must consider is whether to operate
their Speak Up line internally or to use an external provider. Organisations should
identify what would work best for their particular culture by surveying staff.
Best practice would indicate that by involving employees and employees’
representatives (such as unions and works councils) in the process, outcomes
are more likely to be successful.
17 See for example United Technologies: http://www.utc.com/responsibility/ombuds
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Many companies feel providing an internal Speak Up line encourages trust within
their organisation. This tends not to be run by the HR function but by an audit,
compliance or other designated function with responsibility for ethics.
Some companies, use an external provider to run their Speak Up lines. The
provider will route the information back to the company and provide a log, which
is important for any internal audit process. An external phone line may engender
more trust with employees who feel happier talking to someone viewed as
impartial and not part of the organisation (Box 10). An external line also helps to
assure the caller of anonymity or confidentiality. It is particularly useful when the
company has many overseas locations, as most external providers say they have
a means of speaking to people in their own language.
Box 10: Example benefit of an external Speak Up line
Case study provided by Expolink www.expolink.co.uk a provider of confidential
external hotlines.
Organisations set up an external Speak Up line service for many different
reasons and often get unexpected results. One organisation wished to
address the low number of calls received on their internal hotline, which had
been an ongoing issue over a number of years. In their first year using
Expolink's external hotline, they received a ten-fold increase in the number of
calls received on their hotline. They identified a cultural bullying issue within
the organisation that the board was unaware of. The board was immediately
able to address the underlying causes of the issues reported on and as a
result in the following year there was a dramatic reduction in calls received.
However, the number of calls received in following years were still higher than
they had received on their internal hotline.
Although the company could not measure the cost benefit of moving their
Speak Up line externally, they were delighted that they were able to address
issues that could have caused ongoing spiralling employment related costs.
3.5 Anonymity and confidentiality
Assuring anonymity can be a vital ingredient in encouraging employees to come
forward with their concerns. As already cited, 52% of employees who have
witnessed malpractice do not report their concerns for fear of being victimised as
a result.
Organisations have concerns as to how to prevent malicious reports being made
under the protection of anonymity. A detailed investigation process can usually
weed out unscrupulous or vindictive reports whilst protecting the genuinely
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concerned member of staff. Providing a clear message of the disciplinary
consequences can also act as a deterrent.
According to an IBE benchmarking survey 18 none of the companies interviewed
ignored anonymous calls. Some organisations which give rewards for information
received, protect anonymity by using external providers (see Box 11).
Box 11: Anonymity and the use of rewards
Case study provided by Expolink www.expolink.co.uk a provider of confidential
external hotlines
The offer of a reward through a hotline is often considered by the retail,
leisure, gaming and distribution industries, but of course may not suit all
company cultures. If an organisation does offer a reward it faces the
dilemma of how to preserve the caller’s anonymity. One of Expolink’s clients,
as an extension of their hotline service, offers a reward of up to £500,
payable anonymously through Crimestoppers.
www.crimestoppers-uk.org
If a report made through the Expolink Hotline leads to the detection of theft,
fraud or malpractice and the case is proven, then the employee who made
the report is entitled to a reward. The sum payable is set at the company’s
discretion.
The reward can be claimed following the standard Crimestoppers method,
ensuring the protection of the employee’s anonymity, and invariably the
reward is claimed through a nominated bank using a secure PIN
identification process.
3.6 Retaliation
In order for the Speak Up procedure to be credible with employees, organisations
should provide explicit assurances that retaliation against those who Speak Up
will not be tolerated.
Failing to protect those who speak up from retaliation can become costly for
employers. In 2003, those who had been sacked or victimised as a result of
speaking up had won more than £10 million a year in compensation in the first
three years of the PIDA 19 . Tribunal Awards averaged more than £100,000 per
case, with the highest reaching £850,000, but many cases were settled out of
court, some for sums which were estimated to be more than £1m.
18 unpublished survey 2006
19 ‘Whistleblowers win £10m a year’, 30 April 2003 Guardian http://www.guardian.co.uk/uk_news/story/0,3604,946040,00.html
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3.7 Joint ventures, suppliers & family members
It is becoming increasingly good practice for organisations to make their Speak
Up line available for joint venture partners and suppliers to raise any concerns
that may arise when dealing with the company. Such openness can help
information reach the board regarding behaviours in the organisation which may
otherwise go unnoticed, for example, bribery or exploitation of gifts and
hospitality. According to an IBE survey, when a helpline call number is in the
public domain i.e. on a website, it is considered to be open to everyone to use.
No common process has emerged regarding inclusion of joint ventures in a Speak
Up policy. Most do make their company Speak Up line available. Only when they
own or manage the joint venture is the provision of a helpline made mandatory.
In a similar way, organisations may consider making their Speak Up line available
to employees’ family members who may have concerns which the employee feels
unable to raise themselves. An example could be the partner of a victim of
bullying in the workplace.
3.8 Policy format
The policy communicates the commitment that the organisation has made to
provide guidance and help for employees with ethical concerns. It can be included
in the organisation’s code of ethics, or as a stand alone policy. Appendix 3 gives
some sample policies which can be found on the internet. It is important to
consider the user friendliness of the policy and its application. The organisation
needs to recognise the courage it may take for an individual to raise a concern so
the policy and processes need to be as encouraging as possible - some provide a
statement with questions and answers to help illustrate the policy.
The basic contents of any Speak Up policy will include (see Appendix 1):
• A preamble This is a short introductory paragraph or covering letter to the
policy, sent to all employees, signed by the CEO, setting out commitment and
context e.g. the organisation’s ethical values. Here is a good place to make a
statement on the support that the organisation will give to those who raise
concerns in good faith.
• Its purpose This explains what the Speak Up policy is, and gives examples of
issues where employees may have questions or concerns.
• How to raise a concern This section will set out the details of the procedure
which individuals should follow when raising a concern. It should also include
a statement on confidentiality and/or anonymity.
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• What will happen next In this section, the details of the process which the
investigation will follow will be described. It will set out the principles guiding
the recording and investigating of reports, such as confidentiality, protection
and timely feedback and set out what the employee can expect in terms of
time frames for investigations, call backs, and progress reports. It should
also re-iterate the commitment by the company to support the individual
raising the concern.
• List of other supporting documents e.g. guidance for managers, guidance for
staff, code of ethics, posters and desktop reminders available.
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Operating the Policy
4.1 Resourcing
Management commitment to the policy is the main resource required to
demonstrate to employees that they are encouraged to raise concerns, that
support will be given and that they will be respected and taken seriously.
Other issues such as the cost of introducing an external helpline/hotline provider
will vary according to the number of employees onsite (usually the pricing
structure relates to size of organisation). Other costs include printing and
dissemination of the policy and training of all staff, as well as designated internal
contacts and those who will administer the process.
It is important to budget for the maintenance and review of the scheme as
employees will need to be reminded regularly of the policy and the support
available. More guidance on reviewing the policy and procedure is outlined below.
4.2 Handling and logging a report
It is important that employees feel able to raise concerns without fear of
retaliation and that they are confident that their report will be kept confidential.
This assurance should be given throughout the reporting and handling process.
Reports to managers
The first port of call when raising a concern is ideally a line manager. Training of
managers in how to deal with staff concerns about ethical standards will ensure
that concerns are handled in a consistent way throughout the organisation,
(Box 12).
Box 12: Guidance for managers on dealing with employees’
ethical issues
• What are the facts of the situation? Are they clear?
• Who is [which stakeholders are] affected by the situation and how?
• What does the code of ethics say about the issue?
• Who should have input to, or be involved in, resolving this issue?
• What are alternative courses of action? Try to think of a ‘creative’ solution.
• Consider a worst-case scenario for your preferred alternative to see how it
affects the stakeholders. Rethink and revise your preferred alternative if
necessary
• Communicate and implement the decision quickly
• What can you do to prevent the situation from re-occurring?
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If the concern is of a more serious nature, reporting can flow upwards through a
choice of contacts, e.g. through line-management, to one or other appropriate
functions in the organisation (e.g. legal department, HR, audit), to a dedicated
company official or to an external ombudsman. Contact can be made directly or
via help lines, and details for these should be communicated in the policy (see
Part 3).
Reports to Speak Up lines
For efficacy and consistency a protocol for receiving calls should be established.
One objective would be to ascertain the seriousness of the report. The following
sample questions may help: (An illustrative call line procedure is in Appendix 2)
• What is the concern?
• Who is involved and how and why?
• Where is this happening? – Is it widespread, or just at your location?
• When did this start or happen (date & time)? How frequently is this
happening? Is this still ongoing? Is it happening within working hours?
• Why is this happening? – What has caused this? What are the consequences
of this?
• What is the scale of the damage or loss?
• How do you know this has happened? Have you seen it directly yourself or
has someone else told you?
• Does anyone else know about this? Are you able to tell me who they are?
(Reassure the caller that they will not be in trouble for not saying anything,
but it might help the organisation to gather evidence).
A confidential audit trail of conversations/emails with callers and responses to
them as well as the details of any internal investigation must be kept. This is
particularly important if a legal case may arise from the call. This could be in a
central database held internally within the HR department or the department
where responsibility for the Speak Up line is held. All calls should be logged and
the facts of cases archived in line with the organisation’s practice.
It is important to let the employee know what they can expect in terms of time
frames for investigations, call backs, and progress reports.
Examples of assurances given to those who report a concern could be:
• A written summary of your call will be sent to the appropriate company
personnel to investigate the concern raised
• Feedback will be given to you
• We undertake to investigate all concerns promptly and as confidentially as
possible
• We undertake to take all necessary actions to improve behaviours.
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4.3 Investigations
Once a call has been logged, an investigation needs to be started to address the
issue. As far as is practicable, it is advisable to minimise those involved in the
investigation process for confidentiality reasons. It is helpful to have a preappointed
investigations panel including for example the head of HR, of Internal
Audit, Finance, and Legal.
Throughout the stages of an investigation, reporting back to the concerned
employee has to be built in so that they feel that their report is being taken
seriously and investigated. If not, the organisation runs the risk of the employee
taking their concerns to outsiders and confidence in the Speak Up programme
being undermined.
There may be occasions when the caller is implicated in the misconduct. In these
cases, the organisation would still need to handle the disclosure in a way that
protects the caller from reprisals. However, the caller should be made aware that
the act of speaking up does not protect them from the reasonable consequences
of any involvement in misconduct, but, in some circumstances, their
admission may be a mitigating factor when considering disciplinary or other
action.
A target timescale for investigations can be helpful, although understandably the
complexity of the complaint may determine the speed with which it progresses.
Most organisations have a process for monitoring the progress of reports and set
time limits where practical.
Classifying the concern as a management or an ethical issue will assist in
identifying a way forward. Does management need more support or does the
problem and solution lie in a change in the wider corporate culture? Can the issue
be prevented from arising again? If necessary, what appropriate disciplinary
action will be taken?
Substantiation
The main purpose of an investigation is to see if any allegations made can be
substantiated. Substantiation can be full or partial. For example, evidence
proving that a single allegation was correct would be fully substantiated, whereas
a multi-allegation case could be either fully or partially substantiated. These
details will be important if there is any subsequent dismissal or criminal
investigation undertaken.
However, unsubstantiated cases may still require actions to be taken. For
example, if there was an allegation of bullying which provided no witnesses and
therefore could not be substantiated, monitoring the department where the
allegation arose, or suggesting the department have some training in the antibullying
and harassment policies of the organisation may be a positive action.
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4.4 Escalating a local concern to head office
In a recent IBE survey of larger companies with Speak Up procedures, the
involvement of head office was shown to depend upon the seriousness of the
report. Some procedures require that all reports come to head office to be
logged. Others rely upon the discretion of regional or business managers. Issues
involving a criminal offence e.g. fraud, were in all cases reported to head office
as a matter of course. Where there were board committees whose remit included
risks or integrity issues, they required regular information on the use (or misuse)
of call lines.
Below are some examples quoted in the survey of different companies' procedures:
• Regular reports of calls are made to the local Audit Committee, if applicable
but important issues are escalated to the Audit & Risk Committee / Audit
Committee at the corporate headquarters
• The Group Director of Human Resources coordinates the process
• All cases reported to Corporate Ethics and Compliance are logged into a case
management system and a compliance officer determines how they are
investigated
• In the US, all reports received are logged in the Ethics Office database and
tracked until resolved. The receipt of reports and their resolution are reported
to the US Compliance and Ethics Committee at their periodic meetings; the
Group Legal Department is also involved. Which function (i.e. ethics office,
HR, etc.) actually investigates the reported allegations depends on the nature
of the allegation
• In the UK, reports are usually raised with the Director responsible for the
relevant department before investigation commences. There is also regular
reporting to Business Conduct Committee with earlier notification to the most
senior levels if appropriate. Reports are given to the Corporate Executive
Committee and the board
• Reports are brought to the Non-Executive Directors of the board who consider
what actions should be taken.
4.5 Monitoring
Reviewing the Speak Up procedure
The Institute of Chartered Accountants in England and Wales (ICAEW) has
produced practical guidance on the obligations for audit committees to review
Speak Up procedures in the revised Combined Code on Corporate Governance
(2003). The ICAEW recommends that boards reviewing their Speak Up
arrangements should ask the following questions 20 :
• Is there evidence that the board regularly considers Speak Up procedures as
part of its review of the system of internal control?
20 Guidance for Audit Committees: Whistleblowing arrangements Institute of Chartered Accountants for England & Wales, 2004
http://www.icaew.co.uk/viewer/index.cfm?AUB=TB2I_63154
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• Are there issues or incidents which have otherwise come to the board’s
attention which they would have expected to have been raised earlier under
the company’s Speak Up procedures?
• Where appropriate, has the internal audit function performed any work that
provides additional assurance on the effectiveness of the Speak Up
procedures?
• Are there adequate procedures to track the actions taken in relation to
concerns made and to ensure appropriate follow-up action has been taken to
investigate and, if necessary, resolve problems which have been highlighted
by calls?
• Are there adequate procedures for retaining evidence in relation to each
concern?
• Have confidentiality issues been handled effectively?
• Is there evidence of timely and constructive feedback?
• Have any events come to the committee’s or the board’s attention that might
indicate that a staff member has not been fairly treated as a result of their
raising concerns?
• Is a review of staff awareness of the procedures needed?
What does success look like?
Effectiveness of this sort of policy is difficult to measure. According to IBE
figures regarding use of Speak Up lines, the range in the number of calls per year
is between 0.5% and 1% of the total workforce. The number of these calls which
are ‘serious’ is very low. However, number of calls is not an effective
measurement of success: just one call can make a difference to a company’s
reputation.
Low numbers may be an indication of suppressed concerns, or that there is an
open culture where people are reporting their concerns to their managers. Higher
numbers may also demonstrate openness and trust or can indicate that the
scheme is being abused. Different countries might expect differing response
levels, depending on general levels of corruption. The Transparency International
Corruption Index can be a useful guide to this. 21 External hotline companies with
the experience of similar sized organisations in a similar sector can provide an
indication of effectiveness. GSK’s experience is set out in Box 13.
21 http://www.icgg.org/corruption.cpi_2006.html
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Box 13: Speak Up at GlaxoSmithKline
Employees are encouraged to seek help and to report any concerns or
suspected cases of misconduct. They can do this through their line
management, a compliance officer, or through our confidential Integrity
Helplines or offsite post office box (in the US).
The Helplines and post office box are promoted through the Employee Guide
to Business Conduct, on the GSK intranet and during training. The Corporate
Ethics and Compliance function is promoted as a source of information and
advice, as well as a mechanism for reporting concerns.
In 2005 there were:
• 3,644 contacts with the compliance functions, mainly in the US. This is an
increase from 2,593 last year.
• Of these, 77% were from employees seeking advice or information; 23%
were from employees reporting suspected cases of misconduct.
• Outside the US, mechanisms to track this information are evolving with
general trends and issues being visible to senior management and
addressed through action where necessary.
GlaxoSmithKline Corporate Responsibility Report 2005
Among the ways of assessing the success of a Speak Up policy are:
• Responses to a question in general employee surveys about the credibility
and accessibility of the Speak Up line
• Comments made in annual appraisals and exit interviews
• Trends in call-line use by different businesses/departments and in different
countries
• Analysis of report outcomes
• By making test calls to see if and how procedures are working.
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Appendix 1
Checklist for setting up an effective
Speak Up policy
Establishing the policy
✔
✔
✔
✔
✔
✔
✔
✔
✔
Establish a mechanism for drawing up the policy and where senior
responsibility lies for this
Understand how the policy will fit with your organisation’s code of ethics
Decide on the scope of the policy: what issues will it cover and which
employees/stakeholders will it apply to?
Decide on what mechanisms are appropriate for assisting and supporting
staff wishing to:
a) make enquiries
b) seek advice
c) discuss or raise a concern
d) report an observed misconduct
Identify further guidance and training needs for managers
Consider the need for an internal ombudsperson and/or an external service
provider
Consider how cultural and juridical differences may need to be accommodated
in overseas countries in the drawing up of the policy and reflected in its
content
Decide on a strategy for communicating the policy and awareness raising
among different staff groups, geographies and cultures
Decide on mechanisms and metrics for monitoring policy effectiveness
Policy format
✔
Check the policy includes:
✔ Preamble from CEO or senior director
✔ The purpose of the policy
✔ Principles that guide the policy such as ethical values, legal requirements,
non-retaliation, confidentiality etc
✔ What types of issue are covered by the policy
✔ Guidance on how staff can seek assistance when they have an enquiry or
concern
✔ Encouragement for employees to speak to their colleagues, line managers
or other managers if appropriate
✔ What staff can expect if they Speak Up: e.g. how their concern will be
handled and what action might be taken
32

SPEAK UP PROCEDURES
APPENDIX 1
✔ The role of any call lines/web pages: when to use them and how they can
help
✔ Procedures used for investigating calls and providing feedback to the caller
✔ Warning of disciplinary action for malicious use of the line.
Communication
✔
✔
✔
✔
✔
✔
✔
✔
Select a user friendly name for the policy
Select a user friendly name for any call lines. Consider how trust can be
improved in the choice of name for this service
A call line number should be available and communicated to every employee
Decide on how to communicate the policy:
✔ By leaflet/hardcopy
✔ By intranet site
✔ Through staff training
✔ With ‘gimmick’ support such as mugs, pens, mouse mats
✔ Internal poster campaign
Identify training opportunities for raising awareness of the policy
Test with an employee group to ensure that the language and terminology
used is encouraging
Be aware of legal, cultural, ethnic and religious factors which may need to be
reflected in how this policy is communicated and operated
Identify how generalised cases of the ‘policy in action’ may be communicated
to staff, e.g. in staff newsletters.
Implementing the policy
✔
✔
✔
✔
✔
✔
✔
Appoint the person or function who will oversee the operation of the policy
Provide training for managers on the processes involved in encouraging staff
to discuss concerns and how to handle them
Establish a clear procedure for handling and investigating concerns or reports
of misconduct
Establish how concerns will be recorded, and when and how they will be
cascaded up e.g. to regional or board level
Provide feedback both to the individual and to staff in generic terms after
matters are resolved
Consider including information on the use of the Speak Up policy in the
Annual Report
Build in regular reviews of the policy’s use and effectiveness.
33

SPEAK UP PROCEDURES
Appendix 2
Example of a call procedure
Below is a sample script of a call procedure when handling reports of alleged
wrongdoing. It outlines the process which a Speak Up line operator can follow to
ensure that an employee’s concern is logged and registered fully and that the
caller is put at ease. This procedure can also be adapted for calls for advice only.
Handling reports of alleged wrongdoing
Greet [Good morning/afternoon, ‘Speak Up Line’, give name.
Ask how you can help]
If necessary, put the caller at ease and assure them that the helpline can be used
• to get advice about the Code and the behaviours it requires, or
• to register concerns about an actual or potential breach of the code of ethics
• to register a conflict of interest
and it can also be used by
• managers seeking advice about handling ethics issues
• staff who are uneasy about raising an issue with their manager
• suppliers, business customers or joint venture partners who wish to raise
ethics issues.
Do you wish to report an actual or potential breach of the code of ethics or
seek advice?
If the caller wishes to seek advice, direct them to [HR or similar department, or
follow adapted script].
If the caller wishes to report an alleged wrong doing:
I will ask you a number of questions that are intended to help me to handle
your call and, if appropriate, to arrange for your concerns to be investigated by
a specialist. Your call is [not recorded/is recorded] but I will ask you a number
of questions and complete a confidential form. This is intended to capture as
much information as possible to enable me to make a judgement about what
best to do about the points you make to me. The form will be kept confidential.
Whilst you don’t need proof of what you tell me, you must have good reason
for calling me and I will ask you about that later. What you tell me must not be
malicious or made for your personal gain.
1. Are you willing to give me your name?
Your name will be kept on the form but will be held in a separate, secure,
hand-written record, cross referenced to your case number which I will give you
later.
34

SPEAK UP PROCEDURES
APPENDIX 2
If yes: record it.
If no or uncertain- It would be helpful to me in investigating the facts to have your
name.
If you give me your name but ask me to keep it confidential I will do so
unless (in exceptional circumstances) required in law, in the course of a
criminal investigation by the Police, or in serving a substantial public interest
requirement. It would be helpful to share your name if I appoint a specialist
to carry out the fact finding. He or she will protect your identity from any third
party. We will not reveal your identity to any person who might be involved in
your reported concern. You will be protected from reprisal from having
reported your concern – exacting reprisal is unlawful and a disciplinary
matter. However, you have a right to remain anonymous if you wish. We will
give advice or investigate your case even if you wish to stay anonymous, but
it could make investigating the case difficult, particularly if we need to ask
you further questions or if you want to know the outcome of any
investigations, or if sought, we cannot mitigate any actual, pending or
potential penalties because of any personal involvement, if we do not have
your identity
2. Are you a permanent employee of [ ] or are you a temporary worker,
contractor, former employee, supplier, business customer.
3. (If an employee or temporary worker) Please give me the name of your
business unit and section office and work location.
If only gives location, Executive Director you work for [Business Area]
If not an employee or temporary worker –
please expand on your relationship with [ ] and confirm whether you are
calling on behalf of another organisation (such as a newspaper, a Trade
Union, the Police, private investigator agency, private company or a public
body)
4. In your own words what would you like to tell me about?
[Listen carefully and try to disentangle verifiable fact from opinion, explore why
caller thinks in way he/she does and what grounds for believing he/she has for
suspicion]
Read back to the caller using your notes to verify you have understood their
concern:
• What is the issue? – repeat back your understanding and check it with caller
• Who is involved and how and why? – check your understanding with caller
• Where is this happening? – is it widespread, or just at your location? Is it
happening at another location?
35

SPEAK UP PROCEDURES
APPENDIX 2
• When did this start or happen (date & time), how frequently is this happening,
is this still ongoing? Is it happening within working hours?
• Why is this happening? – what has caused this? What are the consequences
of this? How do you know this has happened? Have you seen it directly
yourself or has someone else told you? Does anyone else know about this?
Do they know you have contacted us? Are you able to tell me who they are?
(They won’t be in trouble because they haven’t told us, but it might help us to
get evidence of the facts)
• What is the scale of the damage or loss (on a scale of large, medium,
small)?
5. Have you spoken to your manager? If so when, to whom and what was the
outcome?
Has this been reported before? Try to clarify anything you don’t clearly understand
(if theft, has it been reported to Police)?
6. Have you reported this to others in [ ]?
(such as HR, or Audit). Has anyone else, to your knowledge, reported this? (when,
to whom, with what outcome).
7. What action, if any, have you taken to date?
(e.g. Activated grievance procedure). Have any actions been taken by anyone else?
8. Are you involved in the incident in any way & if so, how?
If so, mention that guarantees of immunity from consequences cannot be given,
but that the fact that the circumstances have been reported will be taken into
account and may mitigate any penalty that might be given (all assuming identity
has been disclosed – if it hasn’t then no mitigation can be given)
9. What do you want to see happen?
(Allow caller to reply). Let me tell you what will happen next.
10. Next steps. Inform caller:
I will think carefully about what you have told me and, if appropriate, either I will
carry out a preliminary investigation or I will arrange for a specialist or team of
specialists to investigate what you have told me as the basis for what should
then be done.
11. Would you like me to contact you again and, if so, how?
Allow caller to respond.
36

SPEAK UP PROCEDURES
APPENDIX 2
12. Do you want to know how we are progressing the investigation, or like to
know the outcome once decided? (NB – Difficult to arrange if anonymous)
Do you want me to call you at any time in working hours or only at certain times?
Are there any times you would not want me to call you?
Would you like me to use an alias when I call back? (Suggest you do if caller
alleges colleagues or managers will exact reprisal on caller)
What number should we use to call you back on, or should we contact you by
mobile phone, text, post or fax?
I will report the broad outcome of the fact-finding stage to you, if you wish. I will
also report final closure of the case to you and the actions taken, if you wish.
(NB - issue of reporting back to temporary workers or suppliers etc.)
13. Is there anything else you would like to tell me?
Have you told me everything I need to know? Is there anything else that I should
know about before we go any further?
Allow caller to answer.
Your call will be kept confidential. I will decide whether to investigate your call
(and I might take advice about that or carry out a preliminary investigation) and I
will decide whether to appoint an investigator, or a team of investigators. The
investigator will establish the facts and reach a reasoned conclusion; this may
involve management actions. If, in good faith, you believe that reprisals are being
made against you because you have made this call (or you are suspected of doing
so), you should raise this with your manager or Director or with this hotline.
Please note that registration of a call to this service would not, of itself, prevent
any pending action under the Disciplinary procedure or competency arrangements
from being taken.
I am sorry, but I am obliged to tell you that it is a disciplinary offence to make
malicious allegations or to report a wrongdoing for personal gain. Do you wish
me to process this application?
Yes? I’ll give you a reference number that you should use in any future calls or
correspondence (give reference number). Is there anything else you would like to
ask me or that you would like to draw my attention to?
OK, please feel free to call me if you there are any further developments or you
remember anything else that you think I ought to know about or if you think of any
(further) questions you want to ask me.
OK? [if appropriate, I will be in touch by (within X working days of the call)]. Thank
you for your call. Goodbye.
37

SPEAK UP PROCEDURES
APPENDIX 2
Information to be recorded
• Case reference number – year, sequential number
• Date & time of call/ source of reference
• Name of call taker
• Categorise wrongdoing (lining up with code of ethics categories)
• Categorise urgency based upon risks to others (for example, in a traffic light
system: red, amber, green)
• Date of referral to investigating team, preliminary investigation Yes/No
• Name of those on investigating team
• Does the caller threaten to go external?
• Investigating team confirms sufficient information to initiate?
• Interim report from investigating team?
• Outcome communicated to caller?
38

Appendix 3
SPEAK UP PROCEDURES
APPENDIX 3
Some titles of corporate Speak Up policies
and ethics phone lines
Organisation
BHP Billiton
BP
Name of policy
Part of Guide to Business
Conduct (‘Dealing with a concern’)
Part of BP Compliance and Ethics
Programme
Name of helpline
Fraud: Group Audit
Services Fraud Hotline
Ethics: Business
conduct help line
BP OpenTalk Line
Camelot
Diageo
Dimension Data
DS Smith plc
GSK
Lonmin
Merck
Whistleblowing Policy
http://www.camelotgroup.co.uk/
socialreport2005/word-
docs/WhistleblowingPolicy-%2015-
11-04-issue.doc
Part of Compliance Programme
Whistleblowing Policy
http://www.dimensiondata.com/
InvestorRelations/Governance
EthicsAndSustainability/
EthicsAndWhistleblowing/Whistleb
lowingPolicy.htm
Workplace Malpractice Policy
Internal Reporting of Misconduct
and Unlawful Conduct
Whistleblowing Policy
http://www.lonmin.com/Portals/1
/Uploads/About/Governance/
Whistle_Blowing_Policy.pdf
Part of Compliance Program
Confidential helpline
SpeakUp Helpline
Employee Concern
Helpline
GSK Integrity Helpline
Ethics Hotline
Merck AdviceLine
39

SPEAK UP PROCEDURES
APPENDIX 3
Organisation Name of policy Name of helpline
Rio Tinto
Shell
Rexam PLC
Shire
Pharmaceuticals
Group
Signet Group
Statoil
Speak-out Programme
Part of Shell’s General Business
Principles
Protection of Whistleblowers
Whistle Blowing Policy
Part of Code of Conduct
Part of Ethics in Statoil
Speak-out System
Shell Helpline
Raise Your Concern
Compliance Helpline
Divisional TIPs/
whistleblowing
telephone lines
Ethics Helpline
Source: IBE Survey 2006
40

Appendix 4
Some providers of external call lines
SPEAK UP PROCEDURE
APPENDIX 4
EthicsPoint
EXPOLINK
Global
Compliance
InTouch
Public Concern
at Work
Safecall
www.EthicsPoint.com
www.expolink.co.uk
www.globalcomplianceservice.com
www.peopleintouch.eu
www.pcaw.co.uk
www.safecall.co.uk
American based,
international service
provider
UK based,
international service
provider
American based,
international service
provider
Based in the UK,
Netherlands and with
a partner office in
the US
UK based
whistleblowing charity
focusing on
accountability and risk
management.
Provides professional
consultancy/training
and a confidential
advice line for staff.
UK based service
provider
41

SPEAK UP PROCEDURES
Appendix 5
Additional resources
Organisations
Freedom to Care
UK whistleblower support group, promoting the expression of social conscience in
the workplace, public accountability, ethics at work and supporting whistleblowers
and whistleblowing.
www.freedomtocare.org
Government Accountability Project (GAP) US
A non-profit, public interest organisation and law firm in the USA. GAP promotes
government and corporate accountability by advocating occupational free speech,
litigating whistleblower cases, publicising whistleblower concerns, and developing
reforms of whistleblower laws.
www.whistleblower.org
National Whistleblowers Centre (US)
www.whistleblowers.org
Open Democracy Advice Centre (ODAC) South Africa
A non-profit company that supports democracy and helps build accountable
institutions in South Africa by promoting access to information and advising
whistleblowers.
www.opendemocracy.org.za
Public Concern at Work (PCaW) UK
Public Concern at Work is the UK's leading authority on public interest
whistleblowing. Founded in 1993, PCaW promotes best practice across all
sectors by focusing on whistleblowing as a key risk management and governance
tool. In practical terms, it promotes the responsibility of individuals to raise
genuine concerns about malpractice and highlights the importance of encouraging
and making it safe for staff to speak up. Promoting a whistleblowing culture
deters malpractice and provides organisations with the opportunity to effectively
address a risk before serious damage occurs. PCaW does this work by:
• Offering professional advice, training and consultancy services, and a helpline
subscription for employers.
• Providing independent and confidential advice to individuals concerned about
apparent danger or malpractice in the workplace.
• Influencing public policy through research and public education activities.
PCaW's approach builds on and reinforces good internal management as
promoted by PIDA and meets the requirements under Sarbanes-Oxley.
www.whistleblowing.org.uk
Their whistleblowing best practice guide can be found here
www.pcaw.co.uk/pdfs/Best_Practice_Guide.pdf
42

SPEAK UP PROCEDURES
APPENDIX 5
Public Interest Speak-Up Advisors (PISA) Japan
PISA is a Japanese organisation that advises whistleblowers.
www.006.upp.so-net.ne.jp/pisa/
Transparency International
A voluntary organisation dedicated to curbing both international and national corruption.
www.transparency.org
Whistleblowers Australia
Whistleblowers Australia is an association that aims to promote a society in which
it is possible to speak out about vital social issues without fear of reprisal. It
provides information to whistleblowers and organises mutual help groups.
www.whistleblowers.org.au
Whistleblower-Netzwerk
Whistleblower support organisation in Germany.
www.whistleblower-netzwerk.de/
Worldwide Whistleblowers
Canadian International whistleblowing news and information site
www.worldwidewhistleblowers.com/home/index.php
Publications
Chartered Institute of Personnel & Development (CIPD)
Factsheet on Whistleblowing
www.cipd.co.uk/subjects/empreltns/whistleblw/whistle.htm?IsSrchRes=1
DTI Employer’s Guidance to the PIDA
Disclosures in the public interest. Guidance on protection for workers who ‘blow
the whistle’.
www.dti.gov.uk/employment/employment-legislation/employmentguidance/page16186.html
First To Know: Robust Internal Reporting Programs
2004 guidebook developed by TRACE and the International Business Leaders
Forum on developing internal reporting programs. Includes interviews with 30
companies from 10 countries
www.iblf.org/docs/First2Know.pdf
43

SPEAK UP PROCEDURES
Publications
Recent IBE Publications
LIVING UP TO OUR VALUES: Developing ethical assurance
How can boards be confident that their organisation is living up to its ethical values
and commitments?
The premise of this report is that an ethical assurance programme will provide boards
with that confidence and assist in safeguarding the integrity, reputation and
sustainability of their organisation. It provides a practical framework for approaching the
assurance of ethical performance against an organisation’s own code of ethics. The
report will assist executive and non-executive directors understand the need for and
benefits of ethical assurance and consider whether the assurance they have in place is
sufficient and robust. The practical guidance is addressed to those overseeing the
assurance of a board and those providing an assurance opinion. It is intended as an
aid to the development of good practice in a field that is still developing.
December 2006 ISBN 0 9539517 8 2 Price £25.00
MAKING BUSINESS ETHICS WORK: The foundations of effective embedding
In many organisations there is a gap between having an ethics policy and its effect
on the business decisions and behaviour of employees. This report looks at the
reasons for this apparent failure to embed ethical values. This report by Simon
Webley is an examination of the experience of UK companies, recent surveys and
research revealing what can be done to improve the efficacy of ethics
programmes. The practical suggestions in this report will be valuable to
organisations wanting to ensure consistently high standards of corporate behaviour
and overcome the barriers to establishing a meaningful ethics policy.
October 2006 ISBN 0 9549288 2 2 Price £25.00
SUPPLIER RELATIONSHIPS IN THE UK: Business ethics and
procurement practice
Laura Spence examines the complexities of supplier relationships and ethical
procurement practice in the UK. The report explores how companies can achieve
fair relations with their suppliers and particularly considers issues raised in
relationships between large organisations and small and medium sized suppliers.
Three case studies, from Camelot, Waitrose and Toyota, help draw out the issues
and good practice approaches. Guidance on good practice is offered for suppliers
and customers alike.
September 2006 ISBN 0 9549288 1 4 Price £25.00
44

SPEAK UP PROCEDURES
PUBLICATIONS
ETHICS AT WORK: A national survey
What do UK employees consider to be the standard of ethical conduct in their
workplace?
This report by Simon Webley and Polly Dryden details the first national IBE Ethics
at Work Survey. It shows how fulltime staff and management regard their own
behavior and that of their colleagues; makes comparisons with Management
Today/KPMG Forensic survey of managers in 2000 and a US ERC employee survey
in 2003; presents the views of workers on the support they are given in 'doing the
right thing' at work; suggests which employees are likely to be 'the most ethical'
and demonstrates to all employers, the benefit of surveying their staff on ethical
issues and conduct, and the need for clearer ethical guidance.
June 2005 ISBN 0 9549288 0 6 Price £25.00
THE ETHICS OF INFLUENCE: Political donations and lobbying
Should companies seek to influence government policy and political outcomes? If
so, what are the ethical and business issues they should consider when making
political donations and lobbying government?
The Ethics of Influence by David Lascelles analyses current corporate approaches
to the challenges in this increasingly controversial area; sets out the pressures on
companies to seek political influence; offers guidance to business on good
practice and is drawn from interviews with senior business people in the UK, US
and Europe.
June 2005 ISBN 0 9539517 9 0 Price £20.00
45

SPEAK UP PROCEDURES
Notes
46

SPEAK UP PROCEDURES
Notes
47

The IBE Good Practice Guides offer
practical assistance and guidance
for making ethics policies and
programmes effective.
Speak Up Procedures is the first in the Good
Practice series. Drawing on the experiences
of international and UK companies, it:
• outlines why organisations need to
encourage and support staff to make
enquiries on ethical issues, raise concerns
and report misconduct
• provides guidance on what to consider
when establishing a Speak Up policy and
the procedures to implement it
• suggests how to operate the policy
effectively, from providing training to
handling and investigating calls to Speak
Up lines.
All rights reserved. To reproduce or transmit this book in
any form or by any means, electronic or mechanical,
including photocopying, recording or by any information
storage and retrieval system, please obtain prior
permission in writing from the publisher.
Designed & produced by Designline, Havant
Price £15 ISBN 0 9549288 3 0
© IBE www.ibe.org.uk
First published March 2007
by the Institute of Business Ethics
24 Greencoat Place
London SW1P 1BE
Text and cover pages printed on: ????????????
Sourced from sustainable forests, total chlorine free, recycled fibre in furnish