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Taking a Fresh Look at Hotlines: Responding to a Global Focus on Whistleblowers

September 2, 2020, Anti-Corruption Report

Ben Haley is quoted in the Anti-Corruption Report regarding the increased wave of whistleblower complaints during the COVID-19 pandemic. Mr. Haley says, “A company that operates in the U.S., Europe, Africa and Asia could be subject to potentially 30 or 40 different regimes. Just because a company must provide feedback in one country does not mean that companies should automatically provide it in countries where it is not mandated.”

He adds, “I typically advise companies to have a clear policy for their employees so the employees can understand that the company does not tolerate retaliation, and that the company will listen and act in good faith reports on that it receive." That policy does not need to incorporate details from the various laws the company is subject to, but the company’s legal and compliance departments “need to ensure that the company meets every relevant country’s requirements for feedback, responsiveness, confidentiality and anonymity.”

When discussing the costs imposed by various communication methods on employees, Mr. Haley says, “In the U.S., we have fantastic telephony, it’s easy to find an Internet hotspot and communication is largely costless for corporate employees. But if I am a compliance officer and employees in the DRC needed to call me, how would they do it?” He adds, “In one country, the phone is going to be perfectly fine, but in another country, employees can’t afford to be on a 30-minute cell phone call, or they are at a mine in a rural area where there is no reliable network.”

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