By Roy Snell
roy.snell@corporatecompliance.org
Let’s be honest here, we are fighting an uphill battle with regard to employees reporting regulatory and ethical problems. I don’t think we talk about “The Stigma” enough. We want it to go away or be untrue and immaterial. People have a dim view of reporting issues. But there is an easy way to overcome this negative perception of reporting issues. There is “The Stigma” but one simple act by you can overcome it. You just need to give them an “out.”
When I was a compliance officer I wandered the halls. I talked to people. I would make idle chatter for as long as was required, then I would slip in as innocuously as I could… “Seen any problems lately?” Not only did I find problems but I found people were eager to talk. They were eager to talk but they had not used the hotline. They wanted to share what was on their mind but they had not come to me or anyone else in a position of authority. They did not want to initiate the conversation but they wanted to have the conversation. The response to my simple little question… was stunning. I not only found problems sitting right under our oblivious noses, but one of them was huge.
You can set up hotlines, have an anonymous drop box, do surveys, etc. but if you don’t get out and talk to people you are going to miss problems. Some people do not want to tell people in authority they have seen a problem, but they will not lie when you ask them and I believe many of them want to be asked. Think about it. What is in their head when they think about reporting… snitch, informer, stoolpigeon, stoolie, blabbermouth, tattler, rat, tattletale, squealer, mole, tipster, betrayer, infiltrator, plant, traitor, canary, turncoat, defector, etc.? Frankly, it says something about our culture when we have so many derogatory words for one act. No wonder they don’t want to initiate the conversation. Many people are dying to tell you something bad has happened. All their asking you do to is ask them if they have seen wrongdoing. They need an out. Give them the out. Ask them if they have seen any problems. They want to be able to say, “I was asked and I wasn’t going to lie.”
[clickToTweet tweet=”The Stigma: Snitch, Rat, Traitor, Tattletale, Mole, Stoolie, Turncoat @RoySnellSCCE” quote=”The Stigma: Snitch, Rat, Traitor, Tattletale, Mole, Stoolie, Turncoat” theme=”style3″]
Roy, very nice article. I started spending more time on all of our campuses and it has been very beneficial. My additional presence on the campuses have broken through the barrier that existed with the staff regarding the stigma of Compliance.
Although I have not used the question that you wrote about, I will start and let you know if it prompts conversation.
Roy, I heartily agree. As a compliance officer who came up through the ranks I found that connecting with the troops – since I used to be one of those in the ranks – is an invaluable tool. Line staff know where the problems within an organization reside. Especially those issues that seem inconsequential to senior management but may have extreme consequences in the long term. Informal questions like “how are things going”, “what bothers you”, etc. is much better than relying on a hotline.
An excellent point, Roy. There is definitely a muddled message in most societies about the morality of being a “snitch.” I have my law school students watch a clip from the movie “Scent of a Woman” where Al Pacino delivers a speech about how honorable it was for the young star not to be a “rat.” http://www.youtube.com/watch?v=RUE4v1rUpSM
Makes for some interesting discussions. There is a certain percentage of the employee population that just need a little push (like walking the halls) to report something. There are others who will never report because they have this muddled moral code. They put loyalty to their friend who is stealing at a higher level than protecting the company. If the company is particularly mismanaged or treats employees poorly, it is highly unlikely that an employee will want to do anything to help the company, other than the minimum necessary to keep a job.
Excellent – in this present electronic world it is so important to be reachable in person. I believe this is a part of the job responsibilities of a compliance professional, whether you are an officer, director or manager. I experienced the same response even when employees weren’t asked, just my mere presence representing “compliance” they were eager to share what they felt were issues!
Thank you Roy, for this very important message.
One mechanism that is uniquely effective in dealing with “dangerous silence” is to establish an organizational ombudsman, an independent, neutral, confidential, informal office that provides a safe place for any individual to go to discuss concerns, consider the options to seek a remedy, be coached on how to proceed and ultimately have a person skilled in conflict resolution monitor the process. By having access to an advocate for fair process, communications are facilitated at all levels in an organization. Ultimately the Board of Directors should “own” this method to manage risk and receive periodic statistical reports on areas of weakness in policies and personnel that will enhance ethics, compliance and governance.
Thanks for all the great comments.
I completely agree with your comments. I have done the same thing and found the same responses. Of recent, though, with all of the conference calls and video conferencing that pins us to our desks, I find it next to impossible to get out into the field and hallways to make these connections. This is obviously something we should take a conscious effort to do! Thanks for the reminder.
Tricia
The compliance profession was created, in part, because those who came before us were talking and writing rather than finding and fixing.
One solution could be what my compliance officer/manager has done: she too is stuck in too many conference calls and meetings so she has me (the compliance analyst) do daily floor checks connecting with the employees and managers. At least once a week I am able to get her out of her office and join me on the floor check. We have a pretty good rapport with most and its amazing even with that how many won’t report things in writing or approach the office but will stop and tell you something on the way to the break room.
Roy’s article is spot on. There is a second reason why employees don’t make reports. Many don’t believe that the organization will do anything about the problem they report.
So compliance officers must address both reasons in order to make themselves relevant and effective.
As this article implies, what is missing in many organizations is a culture that truly invites constructive criticism. One measurement of this problem is the number organizations that actually have a robust open door policy rather than merely offering lip service. By “robust” I mean, first, one in which employees can raise legitimate issues far enough up the chain of command – and far enough removed from the employees immediate chain of command – that a fair, objective hearing is more likely, and, secondly, one that is supported wholeheartedly and without hesitation by senior management. I would be curious to know how many of your readers are employed in such an organization.
Great post, Roy. You provided a perspective I hadn’t considered- i.e., the stigma of using a hotline or being identified as a whistleblower. Labels are harmful and the all of the ones you listed have such negative connotations that it’s no wonder that reporting uenthical behavior, fraud, theft,etc. is not seen as a positive activity. We certainly don’t want our corporations to be seen as imitating or reflective of attitudes in “the streets” with regard to crime and how it is discouraged to report wrong doing to the authorities (in some communities). Your casual approach to asking questions is a very good alternative to getting information in a non threatening, productive way. Thanks for the tip.
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