The post Confirmed: The most powerful tool for occupational fraud detection appeared first on Whistle Blowers.
]]>
As too many know, discovering fraud at the hands of a trusted insider can be devastating – on a number of levels. Fortunately, experts in investigating ‘occupational fraud’ are providing us with evidence-based insights to direct our anti-fraud efforts.
Invest a few minutes in our analysis of the latest data showing how frauds are detected – and then reflect on whether you are allocating adequate resources to the service that is, unarguably, your greatest ally in the detection of fraud in your organisation.
Unarguably? Yes. The results are unequivocal, and better yet, they have been replicated repeatedly, strengthening what researchers call their ‘validity’. They also have strong applicability across geographic regions, thanks to the Certified Fraud Examiners, specialists in detecting, investigating and resolving fraud cases, who contribute in-depth data from organisations around the globe to the biennial research undertaken by the Association of Certified Fraud Examiners.
Not a fraud fundi? Don’t know the ACFE? Read our Fast Fraud Facts box first!
Let’s get to the crux of the matter. The 2022 ACFE report again showed that the most effective method by which fraud was detected was this:
Referred to as ‘tips’ in the report, this source of intelligence is almost three times more effective than even the second most effective source – internal audit. To be specific, tips were found to be the source of initial detection in 42% of fraud cases, compared to:
Internal audit (16%) | Management review (12%) | Document examination (6%) By accident (5%) | Account reconciliations (5%) | External audit (4%) | Automated transaction & data monitoring (4%) | Surveillance (3%) | Confession (1%) | Advised by law enforcement (2%) | Other 1%
Wait a minute! Surely not? When you contemplate the extent of resources the average medium to large size business is devoting to activities such as internal audit, management review, account reconciliation and the like, it is hard to believe their comparative lower effectiveness in fraud detection.
It may be easier to understand when one considers that insiders are at an advantage when it comes to deceiving their employer:
Little wonder then that unmasking these masters of deception can depend upon the receipt of intelligence from others who suspect or observe the fraudster’s wrongdoing.
Given that tips are clearly tops when it comes to fraud detection, let’s turn to the subject of who these people are that are volunteering this crucial information. Knowing their relationship to you will guide you when you come to communicating your whistleblowing policy and procedures.
Looking at the ACFE 2022 data, we find that 16% of tips were made anonymously, so we do not know what their relationship to the organisation was. But these are the groups that could be identified:
Employees (55%) | Customers (18%) | Suppliers (10%) | Others (5%) | Shareholders (3%) | Competitors (3%)
While employees are clearly the largest single source and deliver the majority of tips, it’s worth noting that a sizeable 45% of the total tips come from other sources. It’s no wonder that the ACFE recommends that your whistleblowing policy communication target both internal and external audiences.
It is clear from the data that two things are on the rise: the percentage of organisations who offer a hotline reporting mechanism to their stakeholders, and the percentage of tips that are received via hotlines as opposed to other reporting methods.
But what we found most illuminating are these two findings:
As an aside, smaller organisations (less than 100 employees) typically suffer greater losses than larger ones, in part due to the fact that they typically take far longer to detect the fraud. They are also less likely to have prioritised the investment in a hotline, not appreciating that these cost-effective services may well be even more justified where employee numbers are small.
The authors of the 2022 ACFE Report to the Nations explain that when fraud is detected proactively, it tends to be detected more quickly and results in lower losses. Conversely, passive detection results in longer running schemes and greater material loss.
Which takes us back to the various methods of detection. Many of these are undoubtedly ‘proactive’. They are practices, personnel, controls and tools that are subject to management attention on a regular, if not daily basis.
Which methods fit the ‘proactive’ description? Well, undoubtedly these would include internal audit, account reconciliation, automated transaction/data monitoring, surveillance and account reconciliation.
But does the way you manage whistleblowing in your organisation qualify as a proactive or passive method of fraud detection? Whether or not you are maximising the most effective known source of fraud detection (by far), all depends upon your approach.
We’re sure you agree that, in light of the above findings, any steps that increase the extent to which your whistleblowing management is proactive will be worth taking!
But where to start?
How about by placing this article on your next executive team agenda and use it to raise awareness and garner support, and then task your various strategic support specialists to collaborate on the development of a draft action plan. The collective wisdom generated when your various governance, risk and compliance functions work together with your internal audit and human resources specialists is what the topic of whistleblowing calls for.
In closing, it is important to mention that the ACFE Report to the Nations contains a host of other content that will guide your fraud prevention, detection and management activities. Remember to visit the ACFE website to download this and other free-to-use, research based resources.
Preventing and detecting fraud can be the difference between sustainability and insolvency – and the work of the ACFE means that your approach to fraud can stand upon the experienced shoulders of certified fraud examiners from around the world. Their message is clear: whistleblowing is the #1 tool for fraud detection.
This value is even greater where organisations make an ethics hotline service available, and where whistleblowing is managed as a proactive rather than passive fraud detection mechanism.
For more information on our Whistle Blowing service, kindly contact us.
Written for Whistle Blowers by Penny Milner-Smyth
A note from Dale Horne, Managing Director at Whistle Blowers Ethics Hotline
Dear Readers
I hope that this article has given you direction and encouragement that will pay off in the form of improved fraud detection in your organisation.
Regular readers of the articles published by Whistle Blowers Ethics Hotline will be familiar with the guidance we make available at https://www.whistleblowing.co.za/insights/.
For example, the following articles will provide further insights relevant to the objective of activating your organisation’s whistleblowing:
As our ethics hotline clients know, we offer fraud awareness learning content – which the ACFE Report to the Nations once again found has a significant impact on the likelihood of your people speaking up about fraud.
As always, please do not hesitate to make contact with me and share your comments and queries arising from these client advisory communications.
Based in South Africa, our service is utilised by clients around the globe, and we are specialists in the management of whistleblowing reports on behalf of clients operating throughout the African continent. For more information about our multi-channel, multilingual ethics hotline service visit our website at www.whistleblowing.co.za.
DALE HORNE | Managing Director | dale@whistleblowing.co.za
The post Confirmed: The most powerful tool for occupational fraud detection appeared first on Whistle Blowers.
]]>The post The Merits of ‘Axe to Grind’ Whistleblowing Reports appeared first on Whistle Blowers.
]]>
When Dale Horne of Whistle Blowers Ethics Hotline asked me to share my thoughts on the subject of ‘malicious reporting’ by anonymous whistleblowers, I jumped at the chance.
As an ethics consultant, I am asked from time to time to review and update an organisation’s whistleblowing policies. More times than not I have the heart sinking experience of reading an existing statement to the effect that they ‘do not tolerate malicious reporting’.
Why ‘heart sinking’? Because I know that it’s often only when someone has an axe to grind that they are galvanised into reporting their knowledge of wrongdoing. And it’s usually information that you need and might not otherwise have received. The motivation behind the report pales into insignificance when it means that you uncover and root out unethical activity.
If you only want whistleblowing reports from individuals who occupy a moral high ground, say goodbye to valuable intelligence.
It happens repeatedly that anonymous reports containing valuable information are made via ethics hotlines, not because the whistleblower was thinking of their employer’s best interests in the first instance, but because they were overcome with negative emotion. Very often it is outrage, a sense of injustice that needs righting, perhaps a wish for revenge, and yes, ‘malicious intent’, that propels vital information into your hands as an employer.
Many whistleblowing reports are made by people who have known about a matter for some time and who may even have participated in the improper arrangement – until something changes.
Let’s take a bribery scheme that I had direct experience investigating as a young manager. It transpired that a factory supervisor only allocated premium pay overtime work to employees who favoured him with a bribe – in this case, one chicken per weekend of overtime. I don’t recall how long the scheme had been operating, but it had certainly been years. Everybody in the factory understood this to be ‘the way things are done here’ – except anyone in a position to take action against the extortive supervisor. The supervisor’s undoing? He increased the ‘fee’ by 100% – from one chicken to two. Outraged at what they now believed to be excessive greed, he was reported by the very employees who had until then been paying the one chicken bribe without a cheep.
Then there was the employee who was well-known amongst his colleagues for running an unauthorised and illegal business from the company premises. Let’s just say there were drinks all round to keep the colleagues quiet – until the moonlighter made a (successful) pass at a colleague’s girlfriend. You guessed it – the dumped boyfriend suddenly felt moved to dish the dirt on his teammate’s side-line business.
Your procurement officers giving inside information to favoured bidders? Chances are you will hear about it from an aggrieved and unsuccessful tender applicant. Your intermediaries paying bribes to secure you sales? Thank goodness for the competitor who rang your hotline.
If the first questions you ask yourself when you receive an anonymous whistleblowing report are ‘who might have sent this?’ and ‘what was their motivation?’, you would not be alone. The danger comes in allowing these questions to cloud your assessment of the potential merits of the report or to justify not undertaking an appropriate investigation.
Failure to investigate a report on the grounds that you suspected the whistleblower had an axe to grind, only to find out much later that it had substance, could leave you red-faced. Simply put, the continued harm to the business from the time of that disregarded report to the eventual uncovering of the matter could lie at your feet.
One thing we can all agree on is the fact that any whistleblowing report should be made ‘in good faith’. While definitions of what it means to act in good faith vary, there is agreement that it means to act honestly and sincerely, without misleading or withholding critical information. We require whistleblowing reports to be truthful, or truthful to the best knowledge of the whistleblower.
What we do not want is fictitious reporting, and it is true that fabricated reports are almost always made with malicious intent. It is this reality that has given rise to the mischaracterisation of all reports made with malice. The mistaken blanket approach to all reports with malicious intent is not only found in organisational whistleblowing policies, but in laws and regulations themselves.
Yes, even in laws, regulations and influential guidelines themselves. A superficial reading of the EU Whistleblowing Directive could have national laws throughout Europe perpetuating this error. But read its Clause 32 carefully and you will understand that its intention is this: Whistleblowers who deliberately and knowingly report wrong or misleading information do not have a right to protection, but a whistleblower who reports truthfully should be protected from retaliation for whistleblowing, regardless of their motive.
If you read the comprehensive standard on whistleblowing management systems, the ISO 37002-2021, you will find an extensive list of suggested questions to ask on receipt of a whistleblowing report and when deciding whether an investigation is warranted. Not one of these suggested questions relates to the motive of the whistleblower.
It should go without saying, except in your whistleblowing policy where it should be explicitly stated, that a whistleblower is not protected from facing the consequences of their own participation in reported unethical activity. This is necessary or else those facing the imminent detection of their wrongdoing by other means could absolve themselves by making a hasty whistleblowing report. Where regulators and other bodies offer rewards for whistleblowing, those who participated in the illegal scheme do not have a right to be rewarded for their information.
Your whistleblowing policy must also specify that the making of fictitious reports is a disciplinary offence. In South Africa, the Protected Disclosures Act provides for fines and imprisonment for the offence of fictitious reporting with malicious intent.
No one wants whistleblowing to be weaponised, and I am not suggesting that we encourage employees to use an ethics hotline as a tool of revenge. However, as long as our policies require that no malicious reports are made, we run the risk of misjudging how we should be responding to reports and fail to undertake warranted investigations.
The words may sound similar, ‘malicious’ and ‘fictitious’, but they are not to be confused. It is the fictitious reports that you do not want. Truthful reports propelled by malice can be an invaluable source of information.
Written for Whistle Blowers by Penny Milner-Smyth, Director, Ethicalways
A note from Dale Horne, Managing Director at Whistle Blowers
I hope that this opinion has given you valuable food for thought. In our next article we will discuss the challenging matter of deterring and responding to fictitious reporting.
As always, please do not hesitate to make contact with me and share your comments and queries arising from these client advisory communications. For more information about our multi-channel, multilingual ethics hotline service visit our website at www.whistleblowing.co.za. Based in South Africa, our service is utilised by clients around the globe, and we are specialists in the management of whistleblowing reports on behalf of clients operating throughout the African continent. Visit our Insights page for many more valuable articles on the management of whistleblowing.
For more information on our Whistleblowing service, feel free to contact us.
DALE HORNE | Managing Director | dale@whistleblowing.co.za
The post The Merits of ‘Axe to Grind’ Whistleblowing Reports appeared first on Whistle Blowers.
]]>The post Do’s & Don’ts for Employers: Encouraging Employee Whistleblowing appeared first on Whistle Blowers.
]]>
Perhaps it’s not surprising that reputation is a top source of risk keeping executives and board members awake at night. Responsible leaders everywhere are more concerned than ever before with the baffling problem of why even loyal and trusted employees with knowledge of workplace ethical misconduct don’t simply speak up.
It’s tempting to look for a silver bullet – perhaps a bag of silver or even a silver medal as a solution, but the evidence suggests that neither are guaranteed to work. In fact, your incentive plans may deter rather than encourage whistleblowing – the very opposite of your intention.
Peril in the promise of financial reward by employers to employees
Far from encouraging employee reporting, financial incentives offered by employers can deter and delay whistleblowing.
This is the clear conclusion from an important study published in Auditing: A Journal of Practice & Theory (August 2017). Hijacking the Moral Imperative: How Financial Incentives Can Discourage Whistleblower Reporting (paywall) by researchers Berger, Perrault and Wainberg is recommended reading, not least of all for its useful review of previous work in the field.
Here are some of the key observations and findings that you need to know about from the full journal publication:
Why would someone attracted by a financial incentive delay reporting? As any employer who has gone down this road will attest, having decided to pay for information you inevitably find yourself developing a ‘payment policy’ – not all information is of equal value. This typically involves setting a minimum threshold for loss above which reporters become eligible for reward, and the introduction of a ‘reward formula’ which increases the amount of award as the extent of loss detected via a report increases.
But what about ad-hoc, post-fact rewards, which were not part of this study?
They can bring their own problems reports one employer, who in retrospect could laugh at the unintended consequence of his actions. Against the advice of his human resources department, he gave a delivery driver a grocery voucher as a reward for vigilance after he spotted his recently-hijacked company vehicle and advised the police of its location. A month later, the driver had his assigned vehicle stolen again. This time, it was his wife who coincidently spotted the allegedly stolen vehicle in an obscure location. The employee was most disappointed when a similar reward was not forthcoming. Talk about hijacking the moral imperative!
Anecdotes of employees setting up schemes in order to claim rewards aside, the findings presented in, Hijacking the Moral Imperative: How Financial Incentives Can Discourage Whistleblower Reporting, cast strong doubt on the advisability of material incentives.
This may leave you feeling shorter on answers than ever before, but the key is unlikely to lie in understanding employees who are attracted by extrinsic incentives to do good. In fact, if you must make special payments to get employees to fulfil their obligation to act in their employer’s best interests, you probably have bigger problems than figuring out how to promote whistleblowing.
Instead, let’s learn from the employees who are deterred from whistleblowing if it means associating themselves with a payment for information scheme. Many people, who might otherwise speak up, find the idea of seeking financial reward to do the right thing to be repugnant. They do not want to be cast in the role of a paid ‘informant’. Assuming, as we hope, that most of your employees fall into this category, what then are the circumstances that would encourage them to report wrongdoing at work?
Promise in the promotion of ‘social courage’
It’s an age-old lesson. If you want to solve a problem, make sure you are asking the right question in the first place. What today’s behavioural scientists are saying is that we must define our question like this: How do we promote social courage in the workplace?
In search of answers to this question, let’s turn to recently-reported, credible studies by Matt C Howard and Joshua E Cogswell of the Mitchell College of Business at the University of South Alabama. You can find their report, The Left Side of Courage: Three exploratory studies on the antecedents of social courage’ (January 2018) in the Journal of Positive Psychology (paywall) or link to Dr Melanie Greenberg’s easy-to-read summary in Psychology Today entitled New Research Shows How to Facilitate Social Courage. What makes us willing to speak up and take a stand?.
Howard and Cogswell found that employee personality and age, factors beyond the immediate influence of the employer, play the most significant role in an employee’s likelihood to display social courage at work. Specifically, employees most likely to speak up are those who demonstrate grit and have proactive personalities. As Greenberg summarises, ‘Gritty people are determined, passionate about their goals and willing to persevere. Proactive people take action to address and fix problems, rather than avoiding’. Another strong influence was found to be employee age: older employees are much more likely to speak up, regardless of their length of service with their current employer.
So apart from ensuring that grit and proactivity are personality characteristics that you select for when recruiting, what can employers do to promote the likelihood that people will speak up when needed? There were circumstances that Howard and Cogswell found to have a positive, if lesser, impact on the likelihood of whistleblowing, and which you can control. We present these in the form of recommendations here:
The study clearly showed that employees were more likely to be influenced by internal (intrinsic) factors than by their perceptions of the benefits or risks speaking up – findings that echo those reported in the previous study on the impact of financial incentives.
Accepting that this key characteristic is not fully under the influence of the employer, future research will focus on identifying the kind of actions that deter and promote social courage. In the meantime, we turn to recent surveys from the ethics, compliance and anti-corruption fields for practical insights.
Countering employee beliefs that deter reporting
What do employees themselves have to say about why they choose not to report ethical misconduct?
Any survey you read will confirm the overriding impact on employees of the fear of retaliation, with negative consequences for their employment status, on the likelihood of reporting to an internal or outsourced hotline.
In their Speak Up Report 2017, Transparency International Ireland surveyed employee beliefs most likely to deter reporting, and the top four of these in descending order were found to be the beliefs that a) reports will not be confidential (this increases both retaliation and social rejection risk), b) corrective action will not be taken, c) anonymity of reporting will not be maintained and d) they will be labelled a snitch.
This is helpful data, as if employers simply turn each of these beliefs into a question, preceded by ‘What can we do to counter the belief that…’, they would have a useful action-planning framework that can be developed through a suitably participative process.
As you do so you will come to the quick conclusion that even non-financial rewards that involve public recognition and exposure will have a strong deterring effect on the likelihood of reporting. If you are thinking of handing out medals, consider how this will inadvertently fuel at least three of the four strongest employee beliefs that you want to counteract.
Increasing employee use of your reporting channels
Don’t feel despondent – there is a lot that you can do as a leader to encourage the reporting of ethical misconduct. In fact, good news comes from the Ethics & Compliance Initiative, a best practice community of organisations committed to creating high quality ethics and compliance programs. Their 2018 Global Benchmark on Workplace Ethics found that reports of misconduct by employees rise 94% when leaders verbally promote workplace integrity.
For a practical source of suggested actions to promote reporting, we turn to the excellent resource Encouraging the Reporting of Misconduct – A Round Table Summary published by the Anti-Fraud Collaboration (November 2017). The AFC is a grouping of professional bodies committed to the deterrence and detection of fraudulent financial reporting. Their recommendations?
Recommendations for the effective achievement of these important outcomes are in turn the subject of many other studies and will be the focus of future articles.
In conclusion
Not only is the strengthening of people’s intrinsic or internal motivation the best way to promote whistleblowing, but the use of extrinsic measures such as financial rewards can deter people from speaking up.
There is no silver bullet solution to the creation of a speak up culture, and it certainly doesn’t lie in a bag of silver or a silver medal. Instead, let’s focus on avoiding actions that dampen or distort the desire to do what is right and on promoting a workplace culture that is more likely to strengthen the social courage of our employees.
Written for Whistle Blowers Pty Ltd, by workplace ethics specialist Penny Milner-Smyth
About Whistle Blowers
Whistle Blowers is an independent ethics hotline service provider to employers operating in over 40 countries across six continents from its base in South Africa. Operating a 24-hour service in 16 languages, their insights from over 22 years of serving a range of sectors are consistent with the key learning points in this article. Find out more about Whistle Blowers here and contact Dale Horne dale@whistleblowing.co.za for more information. Alternatively send us an enquiry and we will get back to you.
Author’s note
This article is written for employers wanting to promote reporting by their employees through internal channels or via a dedicated independent hotline service. These are employers who are committed to ethical and legal business practice.
Financial incentives for whistleblowers, where offered by regulatory bodies to people who report illegal activities by their employer, can be in the public interest and can compensate for loss of earnings arising from the whistleblower’s inability to continue in an employment relationship with the company in which illegal activity is taking place, together with any legal expenses they may incur.
References
The post Do’s & Don’ts for Employers: Encouraging Employee Whistleblowing appeared first on Whistle Blowers.
]]>The post The ABC’s of Corruption – A Guide for Employers appeared first on Whistle Blowers.
]]>
Whether you answered YES, NO, or UNSURE to our question, your strength of confidence should be based on an unambiguous understanding of what corruption is and how it impacts your workplace or organisation.
With headlines focused on ‘grand corruption’ and eye-watering financial losses, it’s understandable that many executives feel comparatively confident that they occupy a moral high ground based on the way their business dealings are conducted.
It is in this comparative confidence that a great deal of risk lies. For corruption is corruption, with all its legal, financial, reputational and social implications, regardless of whether its occurrence is:
Corruption in the workplace can occur at every level
You will often hear corruption described as ‘the abuse of entrusted power for personal gain’. It’s the use of the term ‘power’ in this definition that misleads many into believing that corruption is only perpetrated by people in senior positions who can exercise authority over others, and who can set or vary rules to suit themselves.
The truth is that anyone whose position affords them access to or control of resources and systems can cause a deviation in the way things are supposed to be done. It is this access, together with the skills they deploy, that gives them the power to cause corruption regardless of their level of seniority in an organisation.
Consider the entry-level data capture clerk, who receives a bribe from a syndicate to alter input or provide confidential company information that is pivotal to the success of a corruption scheme. Chances are that this employee does not define themself as having power in the hierarchy, but they can certainly have a powerfully damaging effect on their employer.
In this example, mention was made of bribery. Together with abuse of position, blackmail, extortion and fraud, bribery is to corruption what a screwdriver is to carpentry – a staple of the toolbox that is not required for every project. Simply put, the absence of bribery in a business does not mean that its processes are not being corrupted using other methods.
Understanding the tools of corruption
Let’s take a closer look at the contents of the corruption toolbox.
As each method is brought to life in practical examples, you will see that one or more tools can be used – simultaneously or concurrently. An alphabetic listing coincidentally sees us start with the one that is most widely experienced within organisations.
Mary, a recruitment officer, must only consider applications received via the company’s official application management system. This makes it possible to check that all candidates and the recruiters considering them have followed a fair process. A member of the board walks into the recruitment office and drops a CV on the desk. ‘Do me a favour and get this candidate on the short-list, I won’t forget it’.
The words ‘I won’t forget it’ echo ominously in Mary’s mind. Working in HR, she knows that the board will shortly be considering proposals to downsize the support services and other jobs are hard to come by. ‘Perhaps there is no harm’, Mary rationalises, ‘after all it’s only the short list and she is not the final selector… In fact, if a board member believes it’s ok to bypass the system and there’s a chance that I am going to lose my job anyway, I might as well slip my cousin’s CV into the short-list as well – no-one will suspect we are related’, Mary resolves.
The director is tasked with chairing the appeal of disciplinary hearing. The employee facing dismissal hands the director a private note, saying that if the dismissal is upheld, evidence of his ‘cosy’ relationship with a supplier will be exposed.
A sales representative for a manufacturer of commercial paper shredders has an ear to the ground and hears that Reginald, a buyer working for a potential customer, has a love of fast cars. He arranges through a mutual friend to meet Reg at a social event. He offers him the use of a high-spec BMW to take his family on a road-trip holiday, in return for putting his company on the list of three suppliers to which requests for quotations are sent. Reg happily agrees, especially given the second part of the deal which will score him a ‘commission’ on any actual and future sales.
Your truck driver has been ignored for hours at the border post even though vehicles behind him have been processed. The refrigerated goods he is transporting could start to thaw. A border official who is part of a crime syndicate tells your driver that if he agrees to take on board a crate of unregistered medicines that a crime syndicate need transported across the border for sale on the black market, his transit wait will be over. Why would you trust me to deliver your valuable goods on the other side, your driver asks the border official. ‘Because I am always here, and your job requires you to pass between our countries. The next time you are parked off overnight, waiting for us to attend to your papers, I’ll sort you out the minute you fall asleep’.
Joe is out of town visiting clients, one of whom takes him to dinner and picks up the tab. As they leave, Joe sees that another group of diners have left their bill and receipt on their table. He picks it up and submits it as an expense reimbursement claim on his return to work. It’s so easy to deceive these systems that rely on trust, Joe thinks to himself.
Important points about the tools in practice
A simple description and single scenario of the commonly used tools of corruption cannot do full justice to their effectiveness in action. Given the prevalence of abuse of position and bribery in an organisational context, the following are additional important insights for employers.
Abuse of position
Bribery
Finally, one of the things that these tools of corruption have in common is that they are always deployed in a surreptitious or secretive way. It is the intention of those who seek to corrupt, be this within your organisation or as an outsider in relation to your organisation, that you will not know about it.
________________________________
Let’s revisit the strength of your confidence that no corruption is taking place within your organisation or between it and your suppliers, customers and other third parties.
If your confidence remains high, it will be because you have in place the wide range of measures that are necessary to deter corruption in your workplace. These measures will be the subject of a further fact sheet in the ABC’s of Corruption series.
Text by Penny Milner-Smyth, anti-corruption trends monitor and author.
The ABC’s of Corruption series is commissioned by Whistle Blowers (Pty) Ltd for the private and public sector clients of its independent, multi-channel ethics hotline service, provided on six continents from a base in South Africa.
For sales enquiries about the Whistle Blowers Ethics Hotline please email Managing Director Dale Horne at dale@whistleblowing.co.za.
For more information, please visit www.whistleblowing.co.za.
To benefit from valuable insights for all seeking to create and maintain organisational cultures of integrity, shared by Whistle Blowers, follow our company page on LinkedIn here.
The post The ABC’s of Corruption – A Guide for Employers appeared first on Whistle Blowers.
]]>The post Guide to compliance: 3B of the Protected Disclosures Act of South Africa as amended appeared first on Whistle Blowers.
]]>
Why have the 2017 amendments to the PDA not been widely adopted and incorporated into organisational whistleblowing policies? South African employers are typically highly responsive to amendments to employment-related legislation that is regulated by the Department of Employment and Labour. Perhaps the fact that the PDA falls under the jurisdiction of the Department of Justice and Constitutional Development meant that the amendments simply did not ‘reach’ employers via the communication vehicles and channels they are accustomed to?
With the renewed focus on the critical role of whistlelowers in raising awareness of unethical and corrupt activity, and calls for further amendments to the PDA which will take time, we believe that an immediate step to be taken is for all employers to understand and implement the 2017 amendments.
In support of this process, employers may find value in this simple guide to the ‘duty to inform’ provisions of the Amendment Act.
It’s a widely-held employee belief that there is little point in making a whistleblowing report because it will fall on deaf ears or get swept under the carpet. This perception deters reporting, which is not in your interests as an employer, nor consistent with the objectives of the PDA. The ‘Duty to Inform’ amendments of 2017 oblige employers to provide feedback to whistleblowers in order that those that make reports of wrongdoing receive assurance that the information they have provided has been received and that the appropriate action is being taken in response.
Why do we not routinely give feedback to whistleblowers? In some instances giving feedback is an impossible and even inadvisable action, in others it can be that the need to close the loop with the original whistleblower is simply overlooked. It is also the case that some internal reports are never escalated for the attention of those who would otherwise take appropriate action. And it goes without saying, we can only give feedback to whistleblowers if we know their identity.
In this article we offer a step-by-step guide to applying the ‘Duty to Inform’ requirement, and conclude with some advice for gaining maximum benefit from reports made anonymously through an external hotline provider.
____________________
A Six-Step Guide to the ‘Duty to Inform Employee or Worker’ Obligation
We have approached this guide using a questions and answer approach that we hope will help you navigate the Duty to Inform obligations:
1. Has the whistleblower made their identity known to you (and do you have their contact details)?
2. Is (or has) the whistle-blower been employed in your organisation or are they or have they been in a relationship of service to you by virtue of their position as a consultant, agent or temporary employment service or an employee of such a service provider?
3. If YES, is an investigation going to be undertaken or not?
As soon as reasonably possible but within 21 days, acknowledge receipt of the disclosure in writing, advise that an investigation is to be undertaken, and provide an estimated time-frame for its undertaking.
As soon as reasonably possible but within 21 days, acknowledge receipt of the disclosure in writing, inform the whistleblower in writing that an investigation will not take place and explain why.
As soon as reasonably possible but within 21 days, acknowledge receipt of disclosure in writing, advise that the disclosure has been referred on to another party for a decision. Note: This party then assumes the obligation to apply their mind, decide and inform the whistleblower as follows:
YES – Investigation will take place
As soon as reasonably possible but within 21 days of the referral being received, advise the whistleblower in writing that an investigation will be undertaken, where possible providing an estimated time-frame for the undertaking.
No – Investigation will not take place
As soon as reasonably possible but within 21 days of receiving the referral, inform the whistleblower in writing that an investigation will not take place and explain your decision.
4. What if you cannot decide within these intervals whether or not an investigation will take place? Provide written feedback at least every two months until decision reached: After the first 21-day period, if the matter is not referred to another person or party for a decision, or after the second 21-day period if the matter is referred on, the whistleblower needs to be given written feedback at least every two months until the matter is brought to a conclusion.
5. Is there a limit to the total time that can be spent deciding on whether or not to undertake an investigation? The six month maximum: You have a maximum of six months to advise the whistleblower in writing if an investigation is going to proceed, if so how long it is likely to take, and if not, why not.
6. Advise in writing on conclusion of the matter: Finally, whenever the matter is concluded, the whistleblower must be advised of the outcome of the investigation into the disclosure including any arising action.
____________________
In fulfilling your obligations to inform, there are two further provisions that you need to know about. The first may be a relief but the second significantly expands the scope of your obligations:
Limits on the extent of detail in feedback required: In fulfilling your obligations as set out in our proposed six-step process, you are not required to provide the whistleblower with information that could compromise your ability to prevent, detect or investigate a criminal offence.
The new challenge of your obligation to ‘workers’ and not just employees: If the whistleblower is the employee of your temporary employment service provider you share responsibility for fulfilment of the obligations of the PDA as amended. You also have an obligation in terms of the Act to the workers of your consultants and agents. It is in the nature of whistleblowing matters that all associated communication needs to be handled with great caution to avoid breaches of the prohibition against the ‘occupational detriment’ provisions. Communication becomes even more complex when more than one employer is involved. We recommend that you consider in advance the mechanisms by which you will handle reports by workers who are not your employees, in the context of your relationship with your service providers.
____________________
Applying the ‘Duty to Inform’ Concept to Anonymous Reporting via your Hotline Service Provider
The ‘Duty to Inform’ provisions are likely to be sounding onerous right now, but fulfilling them has a number of benefits. It is these benefits that we often regret not being able to achieve when a whistleblower has chosen to maintained anonymity.
There are times when we would like the ability to correct a genuine misperception and put a whistleblower’s mind at rest. There are times when we have a question or two for the whistleblower that would make all the difference to our ability to investigate their claim. Certainly, we often want to convey our thanks to a whistleblower who has spoken up in an organisation’s best interests.
In the experience of Whistle Blowers Pty Ltd, who have been taking reports as an external hotline provider since 2000 and now operate on six continents, an employer’s engagement with the anonymous whistleblower via the independent service is not only possible but highly advantageous.
Whistle Blowers’ Director Dale Horne explains that all callers are provided with a reference number to use so that they can call back for follow-up purposes while maintaining anonymity. As many callers choose to provide the hotline operator with their contact details on condition of confidentiality, Whistle Blowers is easily able to contact the whistleblower with feedback or follow-up questions on their clients’ behalf.
He adds that employers who make use of this facility not only obtain maximum benefit from the service and the reports received, but often find that the whistleblower is so encouraged by the engagement via a professional third-party that they choose to make their identity known and continue the engagement on a direct, open basis.
Looking forward and a disclaimer
It is hoped that future case law will provide us with further guidance on how the Duty to Inform provisions are to be interpreted and applied. Even if you do not know the identity of a whistleblower, an independent hotline provider can help you to achieve the good intentions of Section 3B of the amended Protected Disclosures Act.
Disclaimer: This document is for information purposes only and does not constitute legal advice, it is recommended that any interpretation queries be addressed to your legal advisor.
For more information about Whistle Blowers see www.whistleblowing.co.za or email Dale Horne at dale@whistleblowing.co.za.
Written for Whistle Blowers Pty Ltd by Penny Milner-Smyth
If you would like to refresh your knowledge of the original Protected Disclosures Act, you can download a copy here and you will find the gazetted Amendment Act here. There is a summary overview on our website here and if you missed the original blog read it now: What you need to know and do: Amendments to the Protected Disclosures Act.
The post Guide to compliance: 3B of the Protected Disclosures Act of South Africa as amended appeared first on Whistle Blowers.
]]>The post Ethics hotline valuable weapon in protection of our flora and fauna appeared first on Whistle Blowers.
]]>
It’s a challenge faced by every business. With growth comes risk, increasing as human and physical resources expand.
Imagine for a moment that you are a custodian of enormous quantities of diverse, high value, fast moving assets – located across millions of hectares.
This is the reality faced by those responsible for the management of national parks and game reserves.
While other organisations employ a range of methods to secure what they procure and produce, there is no ease of stocktaking, surveillance or security when it comes to wild animals requiring protection across vast tracts of land.
Obvious differences aside, there are surprising similarities between national parks and every other sector when it comes to theft: it can occur at the hands of outsiders, or insiders, or insiders and outsiders working together. It often involves corruption, where the scheme architects use methods such as bribery, extortion and fraud to secure the cooperation of those who should otherwise not support their unlawful goals.
In every other sector, information received from key stakeholders – employees, customers and suppliers – plays a pivotal role in fraud detection, and there is no reason why it should be any different for national parks and game reserves. Dale Horne, managing director at South Africa’s Whistle Blowers Ethics Hotline agrees.
He is in a good position to know. At last count, the ethics hotline clients in this sector collectively manage over 20 million hectares of parks and reserves located in Angola, Benin, Botswana, Chad, Central African Republic, Congo, DRC, Kenya, Malawi, Mozambique, Namibia, Rwanda, South Africa, Zambia and Zimbabwe.
‘In many ways the reports that we receive on behalf of our clients who manage parks and reserves are no different from those received from our other public and private sector clients. The difference is that often the whistleblowing report is the only way that the information would ever have become available to the client. And of course, the thieves and fraudsters tend to be called poachers.’ Dale explains.
Whistle Blowers’ ethics hotline client list extends across the private and public sectors, with clients operating in over 40 countries and on six continents, Nevertheless, it is their deep experience in providing a conduit for whistleblowing on the African continent that gives Dale particular satisfaction. With live call answering in multiple languages including Swahili, French, Arabic, Portuguese and all the official South African languages, the Whistle Blowers ethics hotline is well equipped to receive reports relating to wrongdoing affecting parks and reserves in the region.
The experience of attending a rhino dehorning exercise had a profound impact on Dale. ‘It was not only distressing to witness, despite every effort such an intervention is inevitably distressing for the rhino. Even a single report containing useful information that enables the detection and prevention of the maiming or poaching of our endangered species makes offering our hotline service worthwhile’.
The economic importance of parks and reserves
Parks and reserves play a significant role beyond the conservation of fauna and flora. Examples include the provision of significant employment in rural areas, the economy boosting impact of ecotourism, and the maintenance and rehabilitation of critical ecosystems. In some countries in the region, the effective management of national parks is helping to forge stability in areas that have suffered protracted conflicts.
All these benefits are put at risk, together with the future of so many species, because of illegal activity targeting parks and reserves. Protecting endangered wildlife from criminals is a complex challenge requiring the deployment of a range of tools, of which one is the provision of a safe reporting mechanism for those with valuable intelligence.
The multiple stakeholders blowing the whistle for wildlife
With a growing percentage of the constrained budgets of national parks and reserves going to securing their assets from criminals, providing expertly-managed whistleblowing mechanisms is the most inexpensive weapon in the anti-poaching arsenal.
The vast tracts of land under management are impossible to monitor at all times, a fact that criminals take advantage of. Often, people who work in the parks or live in surrounding areas become privy to information about plans and schemes to target a park’s assets, be these animals or plants.
Those who speak up openly when they hear about criminal plans to target wildlife generally live in circumstances that make them easy targets too. Their ability to blow the whistle anonymously can be the only basis on which they will consider sharing their important information.
What this means is that it is insiders who are in the best position to blow the whistle. Through the awareness programmes delivered by Whistle Blowers, parks employees are coming to trust the independence and guaranteed anonymity their service offers.
‘Imagine the psychological burden of dedicating your time to protecting a park’s natural and physical assets, while knowing that you are withholding valuable intelligence about a planned attack that you have heard about in the community or the canteen. The relief that callers express when they have fulfilled their duty by reporting this information is always evident’.
Dale goes on to explain that not all countries in Africa offer the equivalent of South Africa’s toll-free numbers, meaning that a ranger may make use of the SMS Please Call Me facility to make contact with one of the ethics hotline information agents. Growing smart phone penetration means that reports are now also being received via the hotline’s reporting app.
My concern is whether the location of parks in relation to rural communities suffering high unemployment levels could mean that such measures might increase conflict between the parks and their neighbours? Dale is reassuring as our conversation concludes, ‘Poaching for the pot is a reality that is borne out of poverty. We need socio-economic solutions to the hunger that drives good people to engage in illicit activity. Our interest lies with the criminal syndicates targeting our parks and reserves for corrupt, illegitimate gain. These might be local syndicates who steal large amounts of game for slaughter and distribution through legitimate-looking butcheries, or they may be trans-national criminal operations’.
Either way, it is good to know that low-cost, high-value services such as the expert receipt of information can play a role in the detection and deterrence of unethical activity targeting our parks and reserves.
Useful references
You can learn more about World Wildlife Day on the official site at https://wildlifeday.org/
Find out more about the Whistle Blowers ethics hotline service on their website at www.whistleblowing.co.za or email admin@whistleblowing.co.za for more information.
Written by
The post Ethics hotline valuable weapon in protection of our flora and fauna appeared first on Whistle Blowers.
]]>The post ISO 37002: Valuable guidelines for managing whistleblowing appeared first on Whistle Blowers.
]]>
Increasingly concerned that your whistleblower report handling will be found wanting?
You’re not alone. How you handle a whistleblowing report can have significant implications for both your organisation and your whistleblowers. It’s a growing realisation that is keeping executives up at night.
Help is at hand. During 2021, the International Standards Organisation (ISO) published a guidance document that will guide you through a structured approach to the receipt, assessment, handling and resolving of whistleblowing reports in your organisation.
As an independent ethics hotline provider, we have reviewed the ISO 37002:2021 Guidelines for Whistleblowing Management in terms of their potential value to our clients. These are the observations we’d like to share:
We think the greatest value of having the ISO 37002:2021 guidelines within easy reach will be the increased confidence with which executives and support specialists can approach the often-daunting task of handling whistleblowing reports.
The Guidelines can be purchased from the ISO store for your country.
For more information about our independent, multi-channel, multilingual ethics hotline service visit our website at www.whistleblowing.co.za. Based in South Africa, our service is utilised by clients around the globe. Visit our Insights page for more valuable articles on the management of whistleblowing.
The post ISO 37002: Valuable guidelines for managing whistleblowing appeared first on Whistle Blowers.
]]>The post Anti-deterrence: The gaping hole in your whistleblowing policy? appeared first on Whistle Blowers.
]]>
Yes. All your efforts at creating a speak up culture and promoting confidence in the organisation’s ethics hotline can be undone, without a single word being uttered. And you will likely never know it happened.
We know that the fear of retaliation has a powerful deterrent effect on potential whistleblowers. This fear tends to persist even where there is no objective evidence of retaliation in a given workplace. While there are many drivers of what you may think is your employees’ irrational fear of retaliation, the deterrent power of the immediate superior is one that needs more attention.
Board, committee and executive team members reasonably assume that their support for whistleblowing – demonstrated through their investment in systems, the development and communication of policies and the delivery of awareness training – sends a strong, comforting ‘speak up in safety’ message to all corners of the organisation.
The truth is that the majority of employees ‘know’ the values of your organisation via those who are able to determine the quality of their everyday work life – their first-line supervisor or manager.
This is the person who mediates their understanding of organisation policy and practice. It’s the person who your employees experience as all-powerful in determining what the days, weeks and months ahead will hold for them. It’s the person who can ‘explain’, for example, that management are only promoting the ethics hotline because they’ve been instructed by the audit committee to do so. And these same employees know the limits of your executive line of sight, blurred by layers of supervision, let alone your inability to monitor multiple locations. If retaliation was to become a reality, the chances you will recognise it as such cannot easily be relied on.
It’s not to say that all who engage in subtle deterrence are trying to keep information of wrongdoing from reaching your ears. For many, the promotion of an ethics hotline is threatening for a host of reasons other than wanting to conceal wrongdoing.
The fear of fictitious reports by subordinates and uncertainty as to how these will be handled is one. These are, after all, the people who meter out workplace discipline and who themselves have reason to fear retaliation – by disaffected subordinates. Lack of confidence that they can safely navigate a spotlight on the operations under their supervision without their competence coming into question can be another. And there are more.
Fortunately, having identified this threat to the effectiveness of your whistleblowing system, there are steps that you can take that will reduce the extent of deterrent behaviour by your supervisors and middle managers. These steps to acquiring the support of all who supervise others involve both requiring and inspiring compliance:
Your anti-deterrence provisions could simply read as follows:
Any action, utterance or insinuation that has the effect of deterring others from reporting information in terms of this policy is prohibited, as it increases the risk and potential for (organisation name) to suffer harm of a reputational, legal and financial nature.
It is an obligation on all who hold positions of influence over others to promote confidence in the (organisation name) whistleblowing policies and procedures, and refrain from casting doubt on the integrity with which reports of wrongdoing will be handled, either by the employer or by the ethics hotline.
Given the importance attached by (organisation name) to this policy, and the legal obligation to provide employees with effective methods to report unethical conduct, any deterrence of whistleblowing constitutes a disciplinary offence.
Consider too that when a report is being investigated, it is the first-line leader who is in a position to deter team members from co-operating with an investigation – and you will want to include a provision to make such deterrence (effectively obstruction) a disciplinary offence.
Those who may otherwise feel threatened by the prospect of their subordinates making reports of wrongdoing need to understand that there are many reasons why the policy and its procedures are of strategic importance to the organisation.
This includes an understanding of the fact that when ethics risks are known to employees who are uncomfortable speaking up directly, the whistleblowing policy enables the timely internal handling of matters that could otherwise remain concealed, or which could emerge in the public domain causing avoidable reputational harm, long after remedial action is possible.
Instil confidence in your supervisory levels that you will handle reports in a fair and reasonable manner, and demonstrate this in the handling of any whistleblowing reports.
There will occasionally be those whose efforts to deter whistleblowing extend far beyond the subtle. Blatant threats – some of which manifest in actual retaliation – are experienced far too often. This leads to a third recommendation – add deterrence of whistleblowing to your list of unethical activities that you encourage your employees to report. Advise them to report any warnings and threats immediately, be these made by their supervisors, colleagues, suppliers, customers or other third parties. You need to know the extent to which your employees are being deterred from fulfilling their obligation to speak up in your best interests.
When we require those with managerial and supervisory responsibility to be advocates rather than detractors of our whistleblowing policies and processes, and when we inspire them with an understanding of the necessity, we reduce the extent to which threats and fear of retaliation deter your employees from reporting unethical activity. When everyone in an organisation knows that it is not only retaliation for whistleblowing, but any form of deterrence that is prohibited and reportable, it increases the likelihood that such threats will be surfaced by the targets of or witnesses to the deterrence.
As long as we have no idea of the extent to which preemptive deterrence is reducing the likelihood of reports being made in the first place, we can take little comfort from an apparent absence of retaliation for speaking up.
An independently managed, specialist ethics hotline may be the only or the last resort of those who would otherwise not share their valuable information about suspected or known unethical activity affecting your organisation.
Established in 2000, Whistle Bowers (Pty) Ltd offers a full suite of reporting channels to their clients who operate on six of the world’s seven continents. For much more information visit the Whistle Blowers website, and for business enquiries please email admin@whistleblowing.co.za.
You can also call 086 000 5050 (from South Africa) or +27 31 308 0600 (international). Your call will always be answered during our switchboard hours of 07:30 – 16:00 (UTC + 2). Alternatively, complete our enquiry form and we will get back to you promptly.
Don’t miss future editions of articles published by Whistle Blowers (Pty) Ltd – follow us on LinkedIn here.
Issued by
DALE HORNE | MANAGING DIRECTOR | WHISTLE BLOWERS (PTY) LTD
Text for Whistle Blowers (Pty) Ltd by Penny Milner-Smyth
The post Anti-deterrence: The gaping hole in your whistleblowing policy? appeared first on Whistle Blowers.
]]>The post Independent ethics hotline certification achieved for 12th year appeared first on Whistle Blowers.
]]>
The challenging circumstances of 2020 put our investment in people and in advanced technology to the test – and there was no faltering in our delivery of a 24/7 multichannel hotline service to our clients, or in the protection of the identities of the record number who made reports of unethical activity via our service during the year.
Delivering an ethics hotline service in 16 languages across six continents might be our daily preoccupation, but doing so under hard lockdown conditions required a fast deployment of secure contingency plans – that worked.
SAFELINE-EX is a set of best-practice norms and standards for the provision of an independent, external safe reporting facility to organisations. A certification undertaken by The Ethics Institute (TEI), the SAFELINE-EX best-practice norms include the integrity, efficiency and independence of the service, and the protection provided to whistleblowers.
While the norms and associated standards share two objectives, ensuring excellent service and the protection of whistleblowers, the comprehensive audit examines every aspect of the service’s capability, practices and performance.
You will find the full details of the stringent standards that TEI assesses us against here – a highly recommended read if you are looking for comfort and confidence in our service. For those responsible for governance and compliance in an organisation, the standards are a valuable when accounting for your ethics hotline service to your Board and its Committees.
At a time when the media spotlight is shining on the mistreatment of and retaliation against whistleblowers at the hands of employers, it gives us great pride to serve the many public and private sector organisations that are committed to providing both their own people and those in their supply chains a secure way to report unethical conduct.
If you are not already a Whistle Blowers Ethics Hotline client, learn more about us via our website at www.whistleblowing.co.za, and contact Managing Director Dale Horne with any business enquiries. We would love to hear from you.
The post Independent ethics hotline certification achieved for 12th year appeared first on Whistle Blowers.
]]>The post Undertaking Workplace Investigations Into Whistleblower Reports appeared first on Whistle Blowers.
]]>
This heightened focus on best practices in the undertaking of workplace investigations is in fact a worldwide development, and it’s not surprising. Here’s why:
We’ve all been calling on our employees to ‘speak up’, and now that they are, we have to ‘listen up’. Not looking into concerns raised by those who care about the best interests of your business? You run the risk of being seen as sweeping bad news under the carpet. What’s more, word quickly spreads that you aren’t really that interested in the information your employees have to share with you, in turn deterring future reports.
When you decide that an allegation has no merit and does not warrant further investigation you may be right – or wrong. Our clients tell us repeatedly about their misgivings at having dismissed earlier allegations as unfounded without full investigation, only to discover way down the line that they were true. In the interim even greater loss has been incurred or worse damage done.
Not only were more CEOs dismissed around the world last year for failings related to ethics than for financial performance, but boards are increasingly reserving their greatest displeasure for executives who erroneously disregard red flags.
From social media to investigative journalists and regulatory bodies, there is an ever-increasing number of third parties interested in ‘insider information’. Employees frustrated at a lack of response by their managers are more likely to take that information outside the business, either in confidence or via anonymous leaks. When this happens, your ability to control the investigation process is lost.
In South Africa, as is the case in many countries, the Protected Disclosures Act (as amended) requires you to advise an employee or worker who has made a disclosure whether or not an investigation into their report will be undertaken – and if not, why not. It also requires that you advise them in writing, at various intervals, on the progress of an investigation and of what decision is finally made as a result of it.
Given the compelling argument for the undertaking of effective investigations into your whistleblowing reports, why is doing so more the exception than the rule? Here are the two key insights that we have from our clients:
We know that some of you report a sinking feeling when a whistleblowing report appears in your inbox. It’s understandable to hope that the allegations contained in the report you are about to open are without substance. Why? Investigating allegations is never an easy process – it’s actually easier to investigate a loss you have already incurred. Deciding how best to proceed without causing needless collateral damage can be daunting.
If your business is like most, your internal capacity is already fully deployed in the service of your core business. Despite this, an effective workplace investigation typically requires considerable resources, starting with the time you will need to find at short notice to craft a course of enquiry.
By definition, an investigation is required because we are not in possession of all the facts and evidence. Given the need to proceed with sensitivity, and in a manner that will protect confidentiality, the early decisions taken are both critical and complex. As new information is obtained, your investigation strategy needs to be updated and revised, typically requiring strong co-ordination and the short notice availability of a core team.
It’s also possible that you do not retain the range of skills and knowledge required for a given investigation on an in-house basis, and this can lead to the deployment of the seemingly most appropriate internal resources on an ad-hoc basis. This in turn can hamper the effectiveness of an investigation despite the best endeavours of your team. Our clients often find that:
While the direct costs of an investigation can be high, the indirect costs to the organisation can be enormous. To limit these costs and to increase the prospects that an investigation delivers the desired insights and evidence, employers are increasingly turning to professional investigators who specialise in supporting you and your internal team in the process of investigating a whistleblowing allegation.
At Whistle Blowers we support our clients through their investigations in the following ways:
We will never share information from a whistleblowing report with an unauthorised or third-party, and this means you will need to provide the information contained in a report to the members of your investigation team, be they internal or outsourced and more likely a combination of the two.
As the effectiveness of your workplace investigation approach has such a profound impact on the likelihood of people using your ethics hotline in future, we would like to encourage you in your journey towards acquiring strong investigations support.
Above all we recommend that any specialist investigative service you appoint be well experienced in:
Whistle Blowers Pty Ltd is an independent specialist ethics hotline service provider to private and public sector organisations in over 30 countries and on six continents, from its base in South Africa. Established in 2000, Whistle Blowers offers multi-channel reporting facilities that are handled in 16 different languages.
Please do not hesitate to contact Whistle Blowers Director Dale Horne, dale@whistleblowing.co.za, should you wish to discuss the content of this article or the ethics hotline service we offer. Learn more about Whistle Blowers at www.whistleblowing.co.za
Follow Whistle Blowers on LinkedIn.
The post Undertaking Workplace Investigations Into Whistleblower Reports appeared first on Whistle Blowers.
]]>