This Helpline/Hotline Handbook (HHH) is designed primarily for chief compliance officers, chief ethics officers, chief information officers, chief legal officers, those responsible for operating the helpline/hotline system and the helpline/hotline program and those responsible for investigating and reviewing allegations of inappropriate behavior. However, the Handbook will also be helpful to directors, executives and senior managers charged with governance responsibilities to better understand the mechanisms and processes involved in handling inquiries and issues and the information conveyed through internal reporting and metrics about the nature of inquiries and issues and their outcomes. Lastly, the HHH will also assist internal auditors in their efforts to plan assessments and establish assessment criteria.

Perhaps your organization operates is some country in a part of the world that has no national, regional, or local law requiring a helpline/hotline and has not been effected by the extra-territorial reach of the laws of another country requiring a helpline/hotline. Perhaps you operate in a country not yet concerned with augmenting their own investigatory resources by providing incentives of protection to its citizens to report untoward conduct directly to the government. Even if there were nothing to tell you that you must have a mechanism for raising inquiries about proper conduct and reporting suspected non-compliant or unethical behavior, the bottom line is that you already have some mechanism. You even already have a mechanism for anonymous reporting – the unsigned letter whether hand-written by someone who’s writing can’t be traced back to an employee or generated on a computer outside the entity. The real question is do you want a mechanism for making inquiries and reporting issues that makes it easier for people to raise issues with your organization directly so you have the first shot at investigating or do you want a mechanism that makes it easier for people to report to authorities first, leaving your organization in a reactive/defensive mode? The bottom line is that you want the approach that is the least “costly” to your entity – both monetarily and reputationally.

 

 

Section 2.01 The HHP Mandate
While this Guide isn’t designed to be a compendium of laws and regulations that require protections be given to whistleblowers – like anonymous reporting lines --, require a helpline/hotline capability explicitly or prescribe guidelines and requirements on how existing helpline/hotline capabilities must be designed, it is unrealistic to think that your organization operates in a complete absence of any of these three types of laws or regulations. Thirty-seven (37) countries have enacted legislation implementing the Organisation for Economic Co-operation and Development Convention on Combating Bribery of Foreign Public Officials in International Business Transactions ...

You want to use an HHC because it is an efficient approach. Forty-four percent of the million dollar frauds in analyzed in the 2006 Report to the Nation on Occupational Fraud and Abuse conducted by the Association of Certified Fraud Examiners (ACFE) were detected by tips. This rate is more than twice the detection rate by internal audit and three times the detection rate through external audit.