The accolade, in its second year, recognises the tireless efforts and dedication of E&C professionals who are leading the charge to embed integrity and ethics as a core value within their organizations.

Nominated by the Ethics and Compliance and Vault Platform community, these individuals stand out as the movers and shakers of the ethics and integrity space.

The 2024 Integrity Innovators

– Amy Mertz Brown, Chief Compliance and Privacy Officer, Boeing Employees Credit Union 

– Laurel Burke, Chief Ethics & Compliance Officer and In-House Leader, Axiom

– Candace Ciresi, Chief Compliance Officer, Mobileum

– Sam Craft, Global Director, Compliance Training and LMS Management, Alcon

– Claudia Curtis, Senior Vice Presidents, Chief Ethics and Compliance Officer, BD

– Rupert Evill, Founding Director, Ethics Insight

– Linda Frazier, Chief Compliance Officer, TripAdvisor 

– Adam Hunt, Leader (Senior Director) of Global Ethics and Compliance Org, Netflix

– Ellen Hunt, Principal Consultant and Advisor, Spark Compliance Consulting

– Sandhya Sharma Global HR Program Manager, MiQ 

– Joseph Philipose, Senior Vice President, Chief Ethics and Compliance Officer, Emergent Bio Solutions

– Gitanjali Sakhuja, Fractional CCEO, GS Consulting

– Carolina Santos da Silva, Head of Ethics & Compliance EMIA, Bridgestone EMIA

– Sonja Sefrin, Associate Director, Ethics, ING

– Micheal Sheely, Chief Compliance Officer, Payoneer

– Monica Thurman, Director, Ethics and Legal Compliance, Intel

 – LaSalle Vaughn, Chief Compliance, Ethics & Risk Officer, Bestow

– Hitomi Walter, Legal Compliance Lead, Wellcome Trust

– Emma Williams, Director of European Risk & Compliance MLRO, Simpson Thacher & Bartlett LLP

Promoting Active Integrity

At Vault, we believe that companies must be active in their pursuit of flawless integrity. And Vault’s core value – promoting Active Integrity – is at the heart of what Integrity Innovators is all about. 

Everyone selected embodies this value, and exemplifies a commitment and vision to make work a better place for everyone.

Their endeavours are serving as inspiration for the next generation of Ethics and Compliance leadership, showing that integrity is not just a buzzword, but a fundamental principle that shapes organizational culture and success.

Our Innovators have also been earmarked as thought leaders in their field, the ones to watch for the latest trends. 

In coming weeks we will hear from them about the projects they’re most proud of, their vision for creating better ethics programs, and their thoughts on the hot topics within the profession.

Meanwhile, if you’d like to find out more about how innovators are building active speak up cultures in their organizations, get in touch.

The post Revealed: 2024’s Integrity Innovators appeared first on Vault.

We’re moving into a new era of corporate ethics underpinned by voluntary disclosure against the backdrop of an evolving regulatory landscape.

As a result, Ethics managers have an increasingly vital role to play today within their businesses.

But with growing demands from regulation and the many examples of scandals surrounding misconduct that we see emerging, Ethics officers need to up their game.

How can they achieve this in 2024? Let’s take a look at some key steps.

1. Review your organisation’s approach

First things first. It’s time to take stock. Do you feel that your organisation’s approach, processes and infrastructure supporting your ethics and compliance is match-fit and equipped for 2024 onwards and the decade to come? Have you got the right tools and technology in place or are you lagging behind? The following points may help you determine the answers and give you food for thought. 

2. Infrastructure fit for purpose

Even if your organisation has the best ethics officer, you can’t build a system purely on their shoulders. You need to think of developing a top class ethics program, underpinned by leading technology and the right infrastructure. Think of it in a similar way to building a super fast train. You can build the fastest, most impressive train imaginable, but if you’re running on the old tracks it won’t fit or work. That is what the traditional hotline is – an old rusty track that we need to replace with updated, modern materials.

3. Capitalising on Artificial Intelligence (AI)

Those new tracks described above mean a digital platform – a modern hotline powered by AI. Finding an effective AI platform can cut through the outsourced call centre as a solution for employee reporting.  This, in turn, helps Ethics and Compliance Directors to enhance their own value to their organisations by reducing costs and increasing efficacy. AI can provide a company with its own internal hotline without needing to employ a single person. The tech can operate it for you.

4. Enhancing efficiency

There’s always room for improvement when it comes to making your department (and the processes that flow from it) more efficient. Technology is the key here. Here are some questions to help determine whether more efficiency is possible in your program:  Are your current methods for reporting up quick and agile? Are you able to instantly, automatically triage all case management for allocation and assignment? Do your HR applications and software speak to each other seamlessly and integrate well?

5. Build a Speak Up culture

Arguably at the heart and centre of it all is the need to build and advance a speak up culture within your organisation. Not simply to issue instructions, build policies and enforce them, but to encourage, cultivate and stimulate an ethos throughout the business where employees are empowered to expose where wrongdoing is happening – be it bribery, conflict of interest, fraud or something else. Having a system that puts employees first is essential for this so the culture spreads throughout, reaching every individual.

6. Catch up with regulatory trends

We promised five steps, but here’s a bonus sixth – and it’s one that really can’t be ignored. There is an increasing and evolving list of regulations across North America and Europe covering workplace misconduct, such as the Equality and Human Rights Commission, EU Whistleblower Directive and Sarbanes-Oxley Act. We’ve also seen the UK’s financial services regulator, the FCA, begin an investigation into the non-financial misconduct of banks and insurance firms.

Staying on top of this increasingly regulatory scrutiny is critical for Ethics and Compliance Officers.

How can Vault Platform help?

Our solutions can help your organisation with all of the steps outlined above. There are many ways we can support your business and as you build your Speak Up culture, including our AI-powered hotline – Vault Talk – or our new Advanced Routing feature, which supercharges efficiency in case management. 

We believe companies can be protected from major risks – perhaps the next big crisis, scandal or lawsuit – if their people are protected too. Our platform delivers the true opportunity to Speak Up.

Book a call with one of our specialists to find out more.

The post 5 steps Ethics professionals should take this year appeared first on Vault.

1. Reporters Are Choosing To Speak Up

The SEC’s Whistleblower Program received more than 12,300 whistleblower tips in 2022 – a new record. This speaks to the willingness of today’s workforce to Speak Up when they experience or witness misconduct and of the growing pressure on companies to listen to their employees.

The SEC issued approximately $229 million in 103 awards, making 2022 the SEC’s second-highest year in terms of dollar amounts and number of awards. This dollar value indicates just how important whistleblowers and the tips they provide are to the SEC. Organizations should be demonstrating the value of their employees’ willingness to Speak Up too by putting in place safe and accessible internal reporting channels and processes so that they hear about business risks from their employees directly. They can then safeguard against reputational damage and other business risks.

2. Retaliation Will Not Be Tolerated

People are also more willing to Speak Up because the SEC safeguards their anonymity and protects whistleblowers by pursuing individuals or entities who take steps to impede or retaliate against them. Enforcements such as those against the Brink’s Company and the co-founder of a technology company send a clear message that retaliation against whistleblowers will not be tolerated. 

Anonymity is an important consideration for internal reporting channels too. Handily, Vault Platform is designed to provide a safe space for employees to report issues either anonymously, in name, or through the power of strength in numbers (more on this below). Discover how you can combat retaliation in your organization.

3. Individuals Are Held Accountable

Individual accountability is stated as one of the pillars of the SEC’s enforcement program and more than two-thirds of the stand-alone enforcement actions involved at least one individual defendant or respondent in 2022. The SEC even charged several executives under Sarbanes-Oxley (SOX) 304, and ordered them to return bonuses and compensation following misconduct at their firms.

Of course, there are ways companies can mitigate against failure to take action and concerns being ‘brushed under the rug’. For example, Vault’s unique time and date stamp technology provide real-time audit logs to demonstrate concerns have been received, investigated, and resolved.

When it comes to identifying culpable individuals internally, Vault’s GoTogether® feature enables employees to surface a report under the condition they’re part of a pattern, including when another Vault app user in their organization names the same specific individual as an alleged offender. You can then identify any ‘bad apples’ within your organization and take meaningful action, dealing with the issues internally before they grow.

4. The Risks Of ESG Violations

Investors are increasingly interested in environmental, social, and governance (ESG) matters and the threat of ESG violations. A portion of the SEC’s 2022 enforcement was therefore dedicated to these issues with respect to public companies and the accuracy of their disclosures. For example, enforcement actions were taken against BNY Mellon Investment Adviser, Inc. for misleading statements and omissions about its consideration of ESG principles in investment decisions. An investigation into Vale S.A. – one of the world’s largest iron ore producers – revealed that it had misled local governments, communities, and investors about the safety of its dams prior to the collapse of the Brumadinho dam in Brazil, which killed 270 people and caused serious environmental and social harm. If you’re keen to further develop your organization’s ESG strategy and prevent violations, download our ‘ESG Do’s and Don’ts’ ebook.

5. Behaviors Need To Change

One of the key takeaways from the SEC’s results is that while records have been broken in terms of the number of tips received and awards given, this shouldn’t become the norm. Penalties are a deterrent; a way to demonstrate how seriously the SEC treats incidents of misconduct and to set the bar for the workplace of the future. 

Gurbir S. Grewal, Director of the Division of Enforcement, said: “While we set a Commission record this past fiscal year for total money ordered at $6.4 billion, including a record $4.2 billion in penalties, we don’t expect to break these records and set new ones each year because we expect behaviors to change. We expect compliance.”

Looking for an all-in-one system of record where misconduct reports can be safely captured, tracked, and resolved internally? Book a demo today.

The post 5 Lessons From The SEC’s Record-High Enforcement Results appeared first on Vault.

It was so good to meet customers, customers-to-be, colleagues and the wonderful ethics and compliance community at the annual SCCE conference in Phoenix this week. Also, a great opportunity for me to get together with some of our US-based Vaulties – which is nothing but a treat! Here are some of my key takeaways from this year’s conference.

Compliance 2.0 is here

Today, the world of ethics and compliance is all about integrity and ESG. Even in a down market and maybe especially in a down market, the stakes were never higher and compliance leaders now play a crucial role in safeguarding their company, culture, reputation, and resilience.

The new generation

A new generation of ethics leaders has entered the market and they’re asking: “where’s my tech?”. This is an underserved, overlooked corner of the corporate from a technological standpoint. We have a community of professionals carrying out mission-critical work on clunky, manual, antiquated, siloed systems and running on very poor data & analytics capabilities. They deserve better, and now they know it.

Vault Platform stood out at the conference with digital solutions, anticipating the community needs of tomorrow while building the product of the future.

The tailwinds are blowing strong

The DOJ crackdown on corporate misconduct and its recent announcement of policies including individual & executive accountability shift the focus on integrity and compliance in a dramatic way. As one official said during the conference, “this is the moment for the Chief Compliance Officer to shine. The government is powering you to do so”.

A personal win for me: I sat in the audience for one of the sessions, and there was a great panel on stage discussing future trends and leadership in compliance and I realized that everyone on stage is a Vault customer! ❤️

The post This is the moment to shine appeared first on Vault.

If you’re involved with 1:1 interactions with misconduct reporters, whether virtually or in person, we’ve got five handy tips to share to help you make the most of your discussions.

1. Ask the right questions

This may seem like an obvious one, but it’s crucial that you get as much information as you can for the report and subsequent investigation by asking the right questions. When and where the incident occurred are of course important, but also questions such as whether the reporter has any physical evidence of the incident they can share (e.g. emails, photos, or notes), whether they’re aware of anyone else who witnessed or experienced the incident or behavior, and how the incident has affected the reporter both in and out of work. Getting as much information and evidence as you can from the 1:1 will help to build a picture of what occurred and get your investigation off the ground.

2. Be Empathetic to Reporters

Reporters need to know that the company values and respects them and is empathetic to their situation and the impact the incident had on them. As the individual they’ve approached about the incident, your empathy towards their situation will likely make a huge difference to how positively they perceive the wider organization. You may also consider emphasizing how seriously the business takes harassment, discrimination, bullying, and other forms of misconduct and reiterate that these are against the organization’s policies and values.

3. Reassure Reporters That Retaliation Will Not be Tolerated

The Ethics & Compliance Initiative’s (ECI) 2021 Global Business Ethics Survey found that pressure to compromise standards is the highest it has ever been and retaliation rates have skyrocketed, increasing by 35% since 2017. 

It’s important to reassure reporters that retaliation, including termination, demotion, and colleagues acting unprofessionally towards them, will not be tolerated by the business and that the reporter can approach you again should any act of retaliation occur.

4. Submit a Manual Report

Customers of Vault Platform can manually create reports inside the Resolution Hub that come through channels outside of Vault, such as those reported verbally. You can create manual reports during or following a 1:1 with a reporter. 

To create a manual report, navigate to your Resolution Hub report list view where you’ll find the ‘Add Report’ button at the top right. You can then select a report type, add the reporter’s details, and either use the employee directory if the individual is happy to submit a named report, or leave blank or enter alternate contact information for anonymous reporters.

5. Follow Up with Reporters (If Appropriate)

Prior to finishing up a 1:1 with a reporter, be sure to ask if they’d be comfortable with you following up with them, even just to tell them how the investigation is going. For example, one of the decisions that may follow the conclusion of a misconduct report is improving managers’ sensitivity training to help them recognize different forms of discrimination, bullying, and harassment in the workplace. Letting the reporter know that this decision has been made, even if they aren’t a manager or directly impacted by the changes implemented, will help to ensure they know how seriously the business has taken their report.

Many reporters may feel frustrated if they don’t have any exposure to how the investigation is going or whether any changes have already been implemented. If an employee feels that they have not been heard internally, they may post about misconduct on social media platforms, such as Twitter, which could be extremely damaging to a brand’s reputation both internally and externally.

Looking for an all-in-one system of record where all reports can be safely captured, tracked, and resolved centrally? Book a demo today.

The post 5 Top Tips to Make the Most of a 1:1 with a Reporter appeared first on Vault.

Lift Our Voices is a nonprofit initiative (started by Gretchen Carlson and Julie Roginsky) dedicated to creating positive, systemic change in the US workplace by eradicating the laws and business practices that prevent employees from disclosing toxic workplace conditions. They give a voice to those silenced by arbitration clauses and NDAs, raising public awareness through advocacy and education.

Neta Meidav, CEO of Vault Platform, said: “Lift Our Voices support those people silenced by NDAs and arbitration clauses, raising public awareness through advocacy and education. It’s crucial that mission-aligned organizations at the forefront of the workplace revolution come together and make our voices heard, which is why this partnership is so close to my heart.

“At Vault, we’re on a mission to change the world of work by giving companies and their employees a safe place to record, report and resolve misconduct in the most human, confidential, efficient, and legally sound way possible. We’re all passionate about speak-up culture and believe the use of NDAs and arbitration clauses are simply a way for individuals and companies to skate around systemic issues that are harming the public and their own employees.”

ENDS

About Vault Platform

Vault Platform is pioneering “TrustTech,” a new category of workplace technology. Designed to enable risk detection, build a culture where it is safe to Speak Up, and drive operational efficiencies, the Vault products create a confidential space for employees and third parties to submit records of misconduct they experience or witness. With an enterprise-grade case management hub and insights dashboard, Vault Platform is key to supporting the productive growth of enterprise businesses. Vault was founded in 2018 and is based in London, UK with offices in San Francisco, New York, and Tel Aviv, Israel. For more information, visit

www.vaultplatform.com 

About Lift Our Voices

Lift Our Voices (LOV) was launched in December 2019 to create positive, systemic change in American workplaces through the eradication of forced arbitration clauses and nondisclosure agreements for toxic workplace issues. Created and launched by Gretchen Carlson and Julie Roginsky, LOV’s mission is to protect American workers by giving those in toxic work environments the freedom to speak freely about their workplace experiences and free them from the laws and business practices that prevent employees from publicly discussing toxic workplace conditions.

https://www.liftourvoices.org/

The post Vault Platform and Lift our Voices Join Forces appeared first on Vault.

Conversely, in companies where the culture is toxic, where bullying and abusive treatment are considered leadership strengths, where intimidation is a tactic to prevent employees from speaking up, and where the compliance program is window dressing only, misconduct is not just an isolated act, it is woven into the fabric of the company. 

What is Workplace Bullying?

According to Verywell Mind, workplace bullying presents as verbal, nonverbal, psychological, or physical abuse. It involves a range of behaviors including threats; intimidation; being humiliated in front of co-workers; unjustified criticism; excessive monitoring; dismissal of someone’s efforts; pressure to do things they don’t want to do; and taking credit for other people’s work, to name a few. Workplace bullying can be all-inclusive or may target victims based on their gender, race, disability, or another characteristic, but it is always about maintaining power and control.

In some cases, workplace bullying may be condoned or encouraged by a Leadership team and perpetuated by company norms. A hierarchical reporting structure may produce a certain leadership style that is akin to workplace bullying. An employee working under the pressure of unrealistic goals or a compensation structure that incentivizes the wrong behaviors may relieve stress by bullying a co-worker or junior employee. 

Sometimes the hiring process doesn’t screen for candidates with a cultural fit or for character and lets in individuals who don’t prioritize treating employees with respect. Regardless of why or how workplace bullying exists, it continues so long as leadership figures don’t understand its root cause, turn a blind eye to red flags, or worse, are its torchbearers.

Toxic Workplace Culture in the News

A New Republic article claims that the Theranos story is more a cautionary tale about the impact of bullying than it is about the sufferings of rich investors or even the cost to patients and employees. It states: “The real crime, as opposed to the legal one, is what CEO Elizabeth Holmes did to the people on her payroll who tried to tell the truth.”

The first Theranos employee to Speak Up was the company’s CFO who, in 2006, told Holmes that he was concerned they were fooling investors with false promises about their technology. He was fired on the spot and rumors were spread that he was terminated for embezzlement. Over the next nine years, other employees tried to raise the alarm with Holmes and Ramesh Balwani, COO, many of whom were fired too. According to a Daily Beast article, some described themselves as survivors of a startup ruled by “paranoia, subterfuge, bullying, and retaliation.” The environment was one of high turnover, bizarre loyalty pledges, fears of legal retaliation, and the tracking of employees’ hours, email, and computer activity – even those they had lunch with. 

In 2014, Tyler Schultz, grandson of former Secretary of State George Schultz and an intern who had only joined the company eight months prior, sent an email to Holmes telling her that all was not right with the company. After a threatening response from Balwani, Schultz quit and subsequently reported Theranos to New York State’s public health lab under a pseudonym and spoke confidentially to the Wall Street Journal. Like other active and former employees who tried to alert investors, government regulators, and the press, he was also threatened with financial ruin.

The ultimate demise of Theranos came because it was built on a vision of something that did not exist. Workplace bullying and toxicity were used to silence employees’ voices for years and dupe investors and patients, but Theranos’ downfall was inevitable. 

Many other companies like Volkswagen, Activision, and Wells Fargo, which may not have been doomed to failure from the start like Theranos, have nonetheless fallen prey to fraud schemes and misconduct, negligence, and hubris. Toxic cultures and workplace bullying in these companies covered up fraud and misconduct and ensured that the schemes went unchecked and unreported. These behaviors caused harm to employees, customers, third parties, investors, and the environment.

These companies may still have a fighting chance to escape a hole that they dug themselves, but their reputations are still tarnished, and their troubles are far from over.

The Impact of Workplace Bullying

As these examples show, workplace bullying is detrimental to employers, the employees who experience bullying firsthand, and bystanders who bear witness to the bullying of co-workers. It is a negative-sum game.

For employers, workplace bullying leads to a host of headaches, not least of which are costly legal fees resulting from hostile work claims; decreased productivity resulting from disengagement and erosion of employee morale, loyalty, and commitment; high absenteeism and turnover; and a difficult landscape for recruiting new talent. 

For employees – the victims of bullying or their witnesses – workplace bullying erodes their trust and sense of safety and perpetuates their fear of speaking up. In the absence of a healthy speak-up culture, misconduct goes unchecked, and issues that may have been nipped in the bud grow to brand and reputation-damaging proportions. Frustrated employees may eventually walk away, but some will also Speak Up externally to the media, regulatory authorities, or to lawyers. They do so not because they’re defiant troublemakers, but because they’re disappointed believers. 

All of us who have experienced workplace bullying first-hand or who have seen co-workers we care about being targeted by it also understand its impact on mental health; stress, anxiety, difficulty sleeping, fatigue, low self-esteem, hopelessness, and depression.

Moving Towards a Better Workplace

Corporate leadership must defend and protect the dignity of its employees by setting the right example at the top, and role-modeling truth, transparency, trust, respect, inclusiveness, and safety. They must also develop a cadre of managers who can listen, communicate clearly, act ethically with respect and compassion, and think on their feet.

Leaders and managers should have their ears to the ground for signs of trouble and be prepared to hear it, process it, and act on it. They should continuously assess the company’s culture, utilizing the troves of available data to connect the dots and identify red flags. Most important of all, they must act swiftly and with urgency to address any pockets of toxicity.

When employees have confidence in leadership’s willingness to listen, take their concerns seriously, respect and protect them in the process, and fight for organizational justice, they will utilize the processes and tools made available to them to Speak Up for themselves, and on behalf of others, when they have concerns or when they suffer.  When they do, they hold corporate leaders accountable for their actions. Only then can the needle move toward businesses doing the right things and doing things right.

Looking to develop a speak-up, listen-up culture at your workplace? We can help.

***

Frequently asked questions

how to handle bullying in the workplace?

Corporate leadership must defend and protect the dignity of its employees by setting the right example at the top, and role-modeling truth, transparency, trust, respect, inclusiveness, and safety.

How to report bullying at work?

When employees have confidence in leadership’s willingness to listen, take their concerns seriously, respect and protect them in the process, and fight for organizational justice, they will utilize the processes and tools made available to them to Speak Up for themselves.

What is toxic behavior in the workplace?

Toxic cultures and workplace bullying harm employees, customers, third parties, investors, and the environment.

How do you handle a toxic work environment?

Hold corporate leaders accountable for their actions. Only then can the needle move toward businesses doing the right things and doing things right.

The post Moving the Needle on Workplace Bullying appeared first on Vault.

1. Provide Employees With An Internal Reporting Channel

When deciding which reporting solution your organization should make available to employees, it’s worth noting the importance of providing an internal reporting channel. Hearing about and handling issues internally allows you to investigate the report and deal with it appropriately before the issue escalates and damages your brand’s reputation. If you choose an external solution, such as a third-party legacy hotline, there is a greater risk of reports not being dealt with in a timely manner or that systemic issues are overlooked. Employees may see this as a sign that the organization doesn’t take incidents seriously enough, in which case they may leave the business and you only hear about incidents via external channels, such as social media platforms.

Adopting an internal misconduct reporting solution isn’t just better for the business. Evidence also shows that employees would prefer an internal channel to be available. Our Trust Gap survey, for example, found that 84% of office workers believe that internal whistleblowing is vital to ensuring that people are protected from the negative impacts of workplace misconduct.

2. Facilitate Anonymity

Our Trust Gap survey also highlighted how important anonymity is to employees. 81% of employees expect their employers to invest in workplace misconduct reporting channels that provide anonymity to the reporter. Retaliation against reporters comes in many forms, from bullying to losing their job, so it’s important to facilitate reporting mechanisms that make employees feel safe.

Additionally, 76% of office workers believe that an anonymized app-based reporting channel would help support the issue of reporting workplace misconduct and empower employers to support a positive and safe workplace. The Vault mobile app provides your workforce with a trusted and highly accessible way of capturing all relevant details of workplace misconduct. This creates a frictionless experience that encourages people to come forward internally with confidence and without fear of retaliation.

3. Allow Reports to Be Made In-Person

There will always be a subset of employees who would prefer to speak to someone face-to-face in order to give their account of an incident. You should therefore encourage employees to choose the right method for them, whether via an app-based solution or talking through the incident ahead of capturing it digitally.

4. Cater for Those That Prefer A ‘Strength in Numbers’ Approach

As well as seeking anonymity and confidentiality, some reporters would prefer to only report misconduct if others have reported similar incidents. Vault’s GoTogether™ feature enables employees to surface a report under the condition they’re part of a group i.e. when another Vault app user in their organization names the same specific individual as an alleged wrongdoer. It is eight times more likely to be used as the reporting option for women reporting behavioral misconduct like harassment.

This ‘strength in numbers’ approach gives employees more confidence that there are other voices willing to Speak Up and, like them, protect their community and the organization from the alleged wrongdoer.

5. Remember to Listen and Feedback to Reporters

For a Speak-Up culture to thrive, there needs to be a countervailing Listen-Up culture. Regardless of how a report reaches you, it’s crucial to take allegations seriously, provide an empathetic ear to reporters, and create a workplace environment that rewards them and takes action following thorough investigations.

In our recent ‘The Way the Whistle Blows’ webinar, the panel shared some key practical tips for managing investigations, including the importance of listening to reporters and treating them thoughtfully and respectfully. It’s also important to stay in contact with the reporter to the extent possible so that they know what’s happening as a result of their report and to minimize the risks of making headlines for the wrong reasons.

Ready to revolutionize misconduct reporting and resolution for your employees? Book a demo today.

***

Frequently Asked Questions

What is the best way to create a Speak-Up culture in an organization?

In order for a Speak-Up culture to thrive in any given organization, there needs to be a countervailing Listen-Up culture. Regardless of how a report reaches you, it’s crucial to take all allegations seriously, provide an empathetic ear to reporters, and create a workplace environment that rewards them and takes action following thorough investigations.

How can employees be encouraged to Speak Up about misconduct they’ve experienced or witnessed?

Our Trust Gap survey, for example, found that 84% of office workers believe that internal whistleblowing is vital to ensuring that people are protected from the negative impacts of workplace misconduct. Employees can be encouraged to Speak Up through providing them with an internal reporting channel, facilitating anonymity, allowing in-person reports, catering for those that prefer a ‘Strength in Numbers’ approach, and remembering to listen and offer feedback to reporters.

What are some of the risks associated with whistleblowing?

In our recent webinar, we shared practical tips for managing investigations, including the importance of listening to reporters and treating them thoughtfully and respectfully. However, there can be issues associated with whistleblowing, like making headlines for the wrong reasons, so it is crucial to stay in contact with the reporter to minimize potential risks.

What should be done when a report of misconduct is received?

When a report of misconduct is received, it’s crucial to take allegations seriously, provide an empathetic ear to reporters, and create a workplace environment that rewards them and takes action following thorough investigations. Retaliation against reporters comes in many forms, from bullying to losing their job, so it’s important to facilitate reporting mechanisms that make employees feel safe.

The post 5 Top Tips to Encourage Employees to Speak Up appeared first on Vault.

Here’s how E&C professionals can successfully pitch ideas to the Board, Speak Up about an organization’s impact, and be heard.

Recognize The Responsibilities of the Board

Corporate boards wield great power; approving corporate strategy, hiring the CEO, and determining compensation for its senior executives to ensure pay and performance align with stakeholder expectations. With that power comes a long list of responsibilities. 

The Board is responsible for ensuring that employees, company processes, and initiatives follow applicable rules and regulations in the pursuit of its business objectives, and more generally, for oversight of the outputs of the compliance function. This is ever more challenging as the realm of compliance grows and the regulatory environment becomes more complex.

In a keynote address at the Society for Corporate Governance National Conference, SEC Commissioner, Allison Herren Lee, drew the connection between the growing influence of corporations over the social and economic well-being of people and communities and the rising tide of Board responsibilities in climate change, racial justice, and economic inequality.

The Board has significant oversight responsibilities, with an ever-growing emphasis on ESG strategy and ESG-related risks. These obligations flow from both federal securities laws and fiduciary duties rooted in state law. In 2020, The World Economic Forum published a white paper explaining that boards need to integrate ESG into corporate governance out of a recognition that business value creation is increasingly dependent on understanding and managing these risks and opportunities.

With Responsibility Comes Risk 

Directors should understand the businesses they serve and provide real oversight of their unique risks. When they fail to do so, the consequences can be catastrophic. For example, in the case of Boeing, after two fatal crashes in 2018 of their 737 MAX, a suit was filed against current and former Board members and Executive Officers alleging that they failed to monitor safety risks to such an extent that it was no longer a topic of discussion in board meetings, despite numerous safety-related red flags.

The plaintiffs in the Boeing case argued that the disaster was linked to a broader lack of attention to safety by Board members, who reportedly “breached their fiduciary duties to the company by dismantling Boeing’s lauded safety-engineering corporate culture in favor of what became a financial-engineering corporate culture.” As a result, Boeing’s directors were charged with liability for losses incurred by the company and its shareholders resulting from not having exercised proper oversight over the company’s activities. They agreed to pay $237.5 million (minus attorneys’ fees and expenses) directly to the company. 

Help to Establish ‘Tone at the Top’ Governance

When it comes to reporting, companies should consider both their financial performance and how they make a positive contribution to society. To establish Tone at the Top, the Board must role model company values and promote a culture of compliance in everything it does. The Board should set the tone through the diversity of its members, the executive it appoints to lead the company, the decisions it makes on where to focus its attention, and the engagement it expects within the communities in which the business operates.

Diversity at all levels of the company – including at the Board level – must also be top of mind. When the Board prioritizes diversity, it sends the message to its stakeholders that having differences, celebrating those differences, and speaking up for those differences is safe and supported by the company. 

To promote and support good governance, the Board must have a solid understanding of the key risks to its business, proactively seek to integrate them into its decision-making and provide appropriate levels of oversight of these risks. This is where the CCO plays a huge part. Particularly in the ESG space, good governance helps to mitigate the risks and better position a business’s model to stand out as an ESG leader in their industry and better compete for capital.

To establish Tone at the Top and promote and support good governance, the Board must have confidence in the CCO and team to implement an effective compliance program with continuous improvement and forward-looking solutions. This requires a sufficient budget to hire and retain skilled in-house professionals, to adopt new solutions that provide its programs with modern analytical capabilities, and to seek external subject-matter expertise, when warranted. 

Build a Concrete Relationship with the Board 

A recent BDO Pulse Survey reinforces the message that Board members and CCOs need to work hand-in-hand to meet the moment and move into the future. This requires the CCO to cultivate a solid working relationship and partnership with Board members from a place of familiarity and trust. 

The CCO helps the Board and senior executives set the Tone at the Top by driving company values and a culture of compliance throughout all levels of the organization.  The CCO is uniquely qualified to train the Board on compliance and ethics topics (including mandatory Code of Conduct training); by equipping them with the language of culture and compliance; and by including board members as active participants in compliance initiatives including live training and compliance communications.

The CCO is instrumental in helping to create a strong governance foundation by ensuring that the company has the right resources; policies, processes and procedures; and training and controls to meet evolving regulatory and legislative obligations, confront its greatest risks and make informed decisions to protect the business and its stakeholders. They can also help senior management adhere to best practices in disclosures as new and challenging guidance develops.

One of the most important ways the CCO builds a trusted relationship with the Board is through effective, transparent, and impactful communications. The CCO must “meet them where they are” so that communications not only impart subject matter expertise and information that the Board needs to fulfill its responsibilities but is also delivered with the right frequency, tone, and tenor. As an example, CCOs should now be communicating with the Board on the urgency of looming regulatory requirements for ESG disclosure that requires the Board’s oversight and direction. 

Join Forces With Gatekeepers

The CCO collaborates frequently with other gatekeeping functions and can provide valuable information to the Board on their collective efforts to increase transparency and enhance the company’s overall control environment. Likewise, the CCO can provide the Board with important insight into company culture by reporting on results of root cause analyses of employee misconduct, highlighting trends, and demonstrating consistent action taken to mitigate the risks.

Build the Right Team

By building a forward-looking and adequately technology-savvy team, the CCO is well-positioned to talk to the Board about new and creative solutions, including technology solutions in the realm of whistleblowing and risk management, to some of the biggest challenges facing companies today, including the environment, corporate culture, and workplace conduct. 

Ready to revolutionize misconduct reporting and resolution for your employees? Book a demo today.

The post How to pitch E&C ideas to your Board to build a Speak Up culture appeared first on Vault.

What is a Speak-Up Culture?

In a Speak-Up workplace culture, employees are willing and able to ask questions and raise concerns when they witness or experience misconduct. They should be able to do so with confidence that their reports are taken seriously and without fear of retaliation.

For a Speak-Up culture to thrive, there needs to be a countervailing Listen-Up culture. It requires a leadership team and Board that make safe and accessible reporting tools available, listen to the reports with all seriousness, have procedures in place to address them, and incorporate learning back into the business to prevent them from re-occurring. A balanced Speak-Up, Listen-Up culture is vital for a healthy business to thrive without making headlines for the wrong reasons.

Why You Should Review Your Culture

The EU Whistleblower Directive (EUWD) came into effect in December 2021. It directs companies with 250 employees or more working in the EU (including those headquartered outside of the EU but with operations in EU jurisdictions) to make internal whistleblower reporting and resolution schemes available. The Directive aims to protect those who Speak Up about breaches of EU laws from retaliation or recrimination and is a minimum standard that leaves each of the 27 EU member states to define how to establish the necessary protection for whistleblowers.

With the EUWD looming large, corporate misconduct still rampant, and trust impacting staff retention, this Directive should – at the very least – be an impetus for companies to assess their culture and to commit to moving the needle on trust by implementing a Speak-Up, Listen-Up culture that empowers stakeholders to use their voices and that holds leadership accountable to its ethical commitments.

Building Trust

The glue that holds both parts of a Speak-Up, Listen-up Culture together is trust. Leadership teams must trust that concerns are raised in good faith while employees need to trust that they are being heard and protected from retaliation. As Warren Buffet famously said, “Trust is like the air we breathe – when it’s present, nobody really notices; when it’s absent, everybody notices.” Now is the time for companies to evaluate the trust gap between them and their employees.

The news is full of stories of toxic workplace cultures where trust was absent. Some companies that use legacy hotline solutions still fail to provide an environment in which it’s safe for employees to use it or choose not to listen even when employees do use the hotline.

Tone from the Top

When leadership teams or board members turn a blind eye or worse, perpetuate misconduct – when the tone at the top is wrong – corporate culture falters. Therefore, it’s vital that leadership teams and board members adopt a ‘do as I do’ mentality that permeates the organization at every level. When values-based conduct is role-modeled by the leadership team and the Board, a healthy Speak-Up, Listen-Up culture is supported and reinforced in every interaction.

A diverse Board of Directors helps set the Tone from the Top by sending the message that the company is willing and able to listen and respond to the diverse voices of its stakeholders. It is a signal to employees that it’s safe to be their authentic selves and to Speak Up without fear.

More often than not, employees take their cues from their immediate supervisors, so Mood in the Middle is crucial. Ethical leaders are the backbone of an ethical culture, and therefore, managers need to role model ethical behavior. But they also need to be trained on how to create an ‘open door’ policy and listen to and guide their employees, how to escalate reports through the appropriate channels, and how to protect their employees from retaliation. 

Investing in technology

The next step in bridging the trust gap is the adoption of a technology solution in the form of a safe, secure, and agile digital platform that demonstrates a company’s willingness to support a Speak-Up, Listen-Up culture. The platform can also help the company comply with the EUWD’s requirements for establishing a whistleblower scheme and other regulations; effectively deal with reports of potential or actual misconduct, including providing safeguards for confidentiality and anonymity that encourage reporters to report internally first, facilitate getting to resolution efficiently, and identify and address risk patterns and trends through analytics.

The role of Communication

Communication is key to building trust in the system, reinforcing Tone from the Top, and setting the Mood in the Middle. A cross-functional communication plan helps employees and stakeholders know how to report concerns. It reinforces the principles of confidentiality, privacy, and non-retaliation, and clarifies the process and potential outcomes, including fair and equitable disciplinary action. The plan should include a Code of Conduct and related policies, including an investigation protocol, to make sure that stakeholders understand and acknowledge their rights and responsibilities. It should also clarify that leadership is held accountable for its commitment to fair, equitable, and transparent due process.

A Speak-Up, Listen-Up culture is ever a work in progress, so companies need to commit to continuous improvement through employee feedback surveys gauging their experience of the culture and the Speak-Up process. Ongoing enterprise risk assessments and audits, tracking and analyzing performance metrics relative to communications, training, hiring, and retention, among other things, are a crucial part of measuring culture. The insight derived from these elements should be reported on a regular basis to the leadership team and the Board to provide maximum transparency and drive accountability to an ethical culture.

The Benefits of a Speak-Up, Listen-Up Culture

In his 2018 letter addressing CEOs, Blackrock CEO Larry Fink declared that to prosper over time, every company must not only deliver financial performance but also show how it makes a positive contribution to society. Companies that develop and promote a Speak-Up, Listen-Up culture engender trust with their employees, creating a stronger brand reputation and boosting brand loyalty. They can also get ahead of issues before they become bigger ones, minimize the risk of ethical breaches and incidents of misconduct hitting the headlines, and reduce the toll of investigations, costs, penalties, and damages. As a result, their employees will feel safer, respected, empowered, and committed, which in turn improves productivity and staff retention. Not only are these companies better for it, but they are also models for others to follow suit.

Measuring the Benefits

When companies implement a Speak-Up, Listen-Up program, along with a flexible and agile digital reporting platform, their incident report numbers may rise initially with greater employee trust and awareness. This increase in reports made in good faith, in fact, provides more opportunities to listen, do root cause analyses, and take corrective actions to prevent future issues. The company is also likely to see a shortened turnaround time from report to resolution, a decline in reported incidences of retaliation, and a significant drop in the number of concerns reported externally. In addition, employee survey scores should be higher on questions of trust and confidence and lower on questions of fear of retaliation. Just as important, by creating a centralized, documented, and auditable record of all reports, along with their investigation and resolution, companies can demonstrate their best efforts to be better.

Not yet discovered the secret sauce to a Speak-Up and Listen-Up culture? We can help.

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Frequently Asked Questions

What is a Speak Up culture?

In a Speak-Up workplace culture, employees are willing and able to ask questions and raise concerns when they witness or experience misconduct and can do so with confidence that their reports are taken seriously and without fear of retaliation.

How to build employee trust?

The glue that holds culture together is trust. Leadership teams must trust that misconduct concerns are raised in good faith while employees need to trust that they are being heard and protected from retaliation.

How to promote ethical behavior in the workplace?

When leadership teams or board members turn a blind eye or worse, perpetuate misconduct – when the tone at the top is wrong – corporate culture falters. Therefore, it’s vital that leadership teams and board members adopt a ‘do as I do’ mentality that permeates the organization at every level.

What is tone at the top?

Tone at the top is when values-based conduct is role-modeled by the leadership team and a diverse Board, a healthy culture is supported and reinforced in every interaction, and shows that the company is willing to listen and that it’s safe for employees to Speak Up without fear.

The post What Does a Speak-Up Culture Look Like? appeared first on Vault.