The heavy lifting is complete. You’ve written your whistleblowing policy, implemented a whistleblowing platform, and communicated your program to your employees. Everyone knows their responsibilities for receiving and responding to anonymous reports, as well as ensuring the anonymity of whistleblowers. Everything is up and running and working the way it is intended to. So, how do you now measure the success of your whistleblowing program?
Measuring the success of your program is not easy. Traditional metrics you might use with other initiatives don't nicely fit when you look at a whistleblowing program. For example, receiving a lot of reports does not make your program a success or failure. The same goes if you receive only a few reports.
In this article, we will outline what metrics you can look at to understand how your whistleblowing program is performing. We’ll break these down based on:
- Employee focused metrics.
- Whistleblowing focused metrics.
- Management focused metrics.
Employee Focused Metrics
Are Your Employees Aware Of Your Whistleblowing Program?
The first measure of success is ensuring that your employees are aware of your whistleblowing program. We often forget how many messages employees receive and it’s easy for them to ignore an initiative once a new one comes along. It’s essential to cast aside your individual perspective and see things from the eyes of your employees - what have they've heard, what did they understand, and what did they retain. We often believe since we know everything about our whistleblowing program that everyone else should know it, but that’s rarely the case.
Test the knowledge of your program by chatting with employees. Start with understanding if they've heard about your program. If they have, dive deeper into their understanding of your whistleblowing policy and what misconduct they should report. The results might surprise you. While you've focused on whistleblowing the last couple of months, it might be one of five new initiatives your employees encountered. Understand where the knowledge gaps are so you can enhance and improve the ongoing communication about your program.
Do Your Employees Know What Should Be Reported?
A challenge many organisations face is that employees don’t know what misconduct looks like. Some employees are hesitant to report anything. Others report issues that are more complaint-oriented and not misconduct. A lot of the calls into a company's hotline are not employees reporting misconduct, but instead asking what is considered misconduct and whether they should report it.
It’s essential for employees to understand what they should report through your whistleblowing program. A best practice is to provide concrete examples of different types of misconduct. Let employees see specific reportable situations, as well as what should go through other feedback channels. Helping employees to understand what to report will help them take action faster and helps you identify risk earlier.
Do Your Employees Know Where To Go To Report Misconduct?
Closely aligned with knowing about your program is understanding where to go to report misconduct. You might have several channels of reporting, including online, mobile, a phone hotline, and even in-person. Do your employees know the different ways they can report misconduct? Reporting misconduct needs to be easy for employees, and if it's not, they won’t make a report.
Follow up your discussions with employees by testing if they know where to go to report misconduct. Do they understand the different channels they can utilise based on their preference? Do they know where your whistleblowing program lives online and where are phone numbers they can call? Test this with employees to see if there are other issues at play that could hold them back from making a report.
It’s quite common in some organisations that employees don’t often use the corporate intranet. If your whistleblowing program lives there, then you need to find a way to overcome this hurdle. Another example is desk-bound employees versus those that are in the field or mobile. Do those away from a desk know how to submit via mobile phone or utilise QR codes to take them to the reporting page?
Talk with employees to understand their knowledge of how to make a report. These can be focused conversations as well as a question during the course of the day. The results might surprise you, especially if it’s been a couple of months since you have launched your whistleblowing program.
Whistleblowing Focused Metrics
What Percentage Of Anonymous Reports Received Are Legitimate?
Another metric to track is the percentage of reports that are legitimate misconduct. There is always going to be a certain number of reports that are not misconduct related. If these reports are a significant percentage, this could be due to miscommunication about your program. Employees could be confused about what to report, what is considered misconduct, as well as where to report general employee feedback.
When you launch your whistleblowing program, measure all of the reports you receive. Have your case managers tag the reports that are not misconduct related. See how this percentage changes over time and if it’s too high, look at ways to better communicate your whistleblowing program. These changes can include the following:
- Refining the communication of your whistleblowing policy.
- Reinforcing your whistleblowing program through ongoing dialogue.
- Re-looking at the whistleblowing content used in your new employee onboarding.
- Reworking the existing material in your whistleblowing platform.
- Providing examples of misconduct so it is clear when an employee should report it.
How Quickly Do You Respond To A Whistleblower Once A Report Is Received?
Another very quantitative measure of your whistleblowing program is how quickly you respond to a whistleblower. You can measure this for both on their initial report and any subsequent messages they send. While not an “end all, be all” metric, it’s a leading indicator of how seriously your team is taking your whistleblowing program. Set this metric at the beginning and measure it over time to see if it changes. It’s a metric that typically starts strongly, but if you don’t receive many reports, it can decay over time.
Set this measurement at the beginning of your program and look at it quarterly as well as yearly. Ensure your team knows you measure this; it will keep them engaged and ensure they respond quickly to reports and messages. The trick here is to look at it quarterly; like any metric, if you ignore it, the results will go down.
How Often Do You Update A Whistleblower About The Status Of Their Case?
Very similar to your response time is how often you update a whistleblower about the status of your investigation. Again, it’s only one metric, but another that's a leading indicator on the health of your whistleblowing program. Many programs start strong, yet later updates to whistleblowers often fall through the cracks and don't happen.
Set a time metric for how often you update a whistleblower during an ongoing investigation. You can make it even easier by letting your whistleblowing platform do the heavy lifting and automate these messages. These messages help increase engagement with the whistleblower, so they are more apt to answer questions that come up later in your investigation.
Management Focused Metrics
Are You Tracking The Statistics Of Your Reports?
Whistleblowing platforms help you keep track of your program as well as collecting data. These statistics look at how many reports you receive, what type of misconduct is occurring, as well as the data collected during the investigation. By having all of your data related to misconduct in one platform, you can identify problem areas in your organisation faster.
One measure of success is having accurate data, but the more significant measure is if you are using the data you have collected. How often are you looking at these reports? Based on the data in your reports, what are you doing to take action? Set a goal of looking at your data every quarter and analyse it to see if there are any changes. It’s also an excellent time to see if you need to take action based on any trends you see.
Remember that it can take time to have enough data to start building an understanding. For some organisations, this can take six months, for those that don’t receive many reports it can take longer.
Does Your Senior Management Team & Board Have Visibility Into The Results?
Many boards and senior management teams get involved with individual issues of misconduct, especially those with high risk. However, are they exposed to the overall results of your whistleblowing program? Moreover, if so, how often do they receive these reports? Is there a discussion or are they just tucked into overall company report?
Providing your board and executive team visibility into your whistleblowing program is a meaningful way to show results. Visibility does not need to be in the form of continuous data or reports they won’t read. Remember your audience and come up with the data points that communicate what is happening in 2-3 slides. Make these slides something that is part of every quarterly update. You will know your approach is successful when the board knows and expects to see this data.
Is Your Organisation Taking Action Based On Reports You Have Received?
Your whistleblowing program is only truly successful if you take action on the reports you receive. Part of this is taking action on the individual reports, but it’s also taking action based on the big picture your reports are telling. Examples could be a disproportionate number of reports from a particular country, office, or location. Alternatively, perhaps you have seen a recent increase in a specific type of misconduct. The first step is understanding what’s going on, but to be effective there needs to be an action plan to fix any underlying problems. Too often organisations collect data to understand the symptoms, but then do nothing to cure the disease.
A best practice is to take the insight provided to your executive team and put your recommendations for what action needs to take place. A decision of “no action” is perfectly fine, as long as you have thought this out and analysed the data. Make the call for each trend you see and provide this with the information you are sharing each quarter. As part of this process, review your past recommendations and discuss what progress you are making.
Summary
Remember, the success of your whistleblowing program is not whether you receive a lot of reports (your employees are reporting risk, right?) or you receive no reports (yippee - no risk here, right?). It’s whether your employees know what misconduct is, know how to report it, and take action to report when appropriate. If you can get this right, you are ahead of 99% of the companies out there. There are other metrics that we have identified in this article, and you should measure these. However, focus on your employees first - they are the ones identifying hidden risk. It’s the toughest part but also what yields the biggest and best return on your whistleblowing program. Once you have this aced, then move on to the whistleblowing and management focused metrics.
