Check SCCE 2022 Conference summary What Every Compliance Officer Needs to Know by Whistleblower Security

What Every Compliance Officer Needs to Know

Summary from SCCE October 2022 in Phoenix, AZ

Listen Up or Employees Will Not Speak Up

• Speak Up Culture means creating a safe space for respectful two way dialogue
• Employees are speaking up but rarely feel heard
  • Do they know where to go?
  • How can they trust whoever that is?
  • Did they get an acknowledgement, response, follow up or thank you?
• Employees hold back reporting because of FEAR
  • Retaliation
  • Looking bad in front of peers
  • Losing their job/identity as a team player
• “The problem with modern corporate culture isn’t so much about getting employees to speak up, . . .; it’s about getting management to listen up.” Matt Kelly, Radical Compliance 09/08/2021

Social Media Risk

• Employees spend an average of 145 mins a day on social media
• The world is listening

Social Media Risk

• Employees spend an average of 145 mins a day on social media
• The world is listening

• Common Sense Guidelines
  • Employees must make it clear they are not speaking on behalf of the company
  • Employees must use a disclaimer if they speak about the company on social media
  • Use of company logos or brand name requires company approval
  • Employees may not post anything ”discriminatory, harassing, bullying, threatening, defamatory, or unlawful”
  • Taking or sharing photos from non-public areas is prohibited
  • Employees may not post “content, images or photos” that they do not “have the right to use”
  • Internal communications and information must be kept confidential

A Reasonable Process for Managing Employee Complaints

Written Policy – Establish and distribute a written anti-harassment policy… document receipt of this policy.

Define – Provide a clear explanation of prohibited conduct.

Report – Require supervisors to report incidents of sexual harassment.

Complaint Process – Allow employees to make both formal and informal complaints of harassment.

Multiple Avenues – Provide a method for employees to bypass a harassing supervisor when making a complaint.

Protection – Provide assurance that complainant will be protected from retaliation.

Training – Provide for training concerning the policy.

Retaliation is the Silent Killer of Compliance

• Retaliation
  • Is more likely to happen than not
  • Can be subtle and sometimes occur unconsciously
  • Will be known among the employees as the average employee tells 9 people at work before they report it
  • Is the biggest driver in someone NOT reporting waste, fraud, or abuse
• Prevent Retaliation by:
  • Adding it to your risk assessment plan
  • Track reports and complaints
  • Discipline threats and retaliation
  • Tell stories of complaints and how they were resolved
  • Asking people directly about it – they might be too scared to call, but they won’t lie when asked

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