What are some best practices regarding an internal reporting system? The 2012 FCPA Guidance stated, “An effective compliance program should include a mechanism for an organization’s employees and others to report suspected or actual misconduct or violations of the company’s policies on a confidential basis and without fear of retaliation.” The 2019 Guidance further refined this basic requirement for a hotline with inquiries into the effectiveness of your corporate hotline, asking, “Effectiveness of the Reporting Mechanism – Does the company have an anonymous reporting mechanism, and, if not, why not? How is the reporting mechanism publicized to the company’s employees? Has it been used? How has the company assessed the seriousness of the allegations it received? Has the compliance function had full access to reporting and investigative information?” In this podcast, we detail some of the key best practices.
Three key takeaways:
- Get the word out to your employees about your company hotline through a variety of mediums and platforms.
- Train your employees on the use of the hotline.
- Use data from your hotline to continually update and improve your compliance program.