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Speak-Up Program During COVID-19: 5 Tips

What to consider during COVID-19 and more generally

by Viviane Joynes 4 min

    Now that we’re in mid-April 2020, most jurisdictions have been in lockdown for a number of weeks due to COVID-19. Many organisations have already had to make difficult decisions including laying off staff or putting them on furlough. For listed companies, decisions have also included not paying a dividend and for some, deciding to raise more capital. During these unprecedented times and perhaps unsurprisingly, our clients have seen an increase in the volume of whistleblowing reports.

    While whistleblowing reporting channels are a crucial part of any compliance and ethics programme, now more than ever they are your direct link to employees and other stakeholders. As remote working has become the norm, visibility for compliance teams has decreased and therefore relying on employees to report misconduct and ethical concerns has become crucial.

    As business continuity plans are now firmly in place in most organisations and while we still likely have a number of lockdown weeks ahead of us, we wanted to take a moment to review and summarise some key considerations to think about when it comes to your speak-up program.

    1. Proactively communicate your speak-up channels

    As part of your internal communications plan, ensure that employees (and possibly other stakeholders) are reminded of your reporting channels.

    The overall aim with any speak-up programme is to make it as easy as possible for employees to report by providing several channels. In fact, our 2019 Whistleblowing Report revealed best practice to be having at least three channels in place.

    While in most organisations speaking to the line manager would be the preferred option, this is not always possible. So ensuring that you have other channels such as a webform and telephone hotline that ensure confidentiality and anonymity is key. Importantly, if you’re using a third-party provider, ensure that their business continuity measures are in place and that they can manage the reports coming through.

    2. Review your speak-up policies and procedures

    There’s a lot going on at the moment and priorities are constantly shifting. Within this context reviewing your speak-up policies and procedures may not seem like a priority. However, neglecting this could have detrimental effects.

    Firstly, ensure your policy is up to date. More specifically, ensure that: the reporting channels are correct, the policy takes into account what to do when working remotely and what reporters should expect when they submit a report.

    Secondly, ensure your investigation procedures and action plans remain relevant for the current situation. As compliance and ethics teams work remotely, there is a risk that reports fall through the cracks and this could have serious consequences for your organisation. It’s particularly important during this time of uncertainty that investigation processes are robust and that reports are responded to in a timely manner.

    Other questions to consider:

    • Do the steps that need to be taken during an investigation need to be adjusted?
    • How will interviews be conducted?
    • Has anyone key to the process been laid off or placed on furlough and therefore, who will take responsibility?
    • Can you continue to guarantee confidentiality?

    If your organisation doesn’t have clear procedures when it comes to investigations, now is a good time to put them in place.

    3. Review submitted reports

    Review submitted reports on a regular basis. By putting time in the diary at periodic intervals (the frequency can be determined based on what’s right for your organisation) you will be able to identify trends. Some questions to consider:

    • Has the number of reports increased or decreased compared to previous years?
    • What risks are arising and are there any new areas of risk?
    • Are there any blind spots within the organisation in terms if risk assessment and training?
    • Does training in certain areas need to be adjusted or redeployed?
    • Do therefore need to be different approach to training in these circumstances? For example, consider whether some bite-sized pieces of information/training could be added to your communications plan.

    4. Digitise your processes

    It’s clear that while everyone is working remotely, having online systems that allow for collaborative working with permissions management, clear workflows, secure communication channels and document storage has never been more important. Using email and traditional document storage is open to human error that can easily put the confidentiality of a case at risk.

    Therefore ensure that your systems and processes are robust and don’t increase the risk of data privacy breaches.

    5. Build trust

    During this unprecedented time, organisations have an opportunity to build trust with their employees and stakeholders. Communicating proactively, clearly and transparently helps to build trust. By showing that you are open, available to manage reports when they come through and responding appropriately will show employees that their concerns are being taken seriously and acted upon.

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    Viviane Joynes
    Viviane Joynes

    Managing Director – EQS Group | Viviane is Managing Director of EQS Group’s UK Business. She has extensive experience of advising UK and European companies on their corporate governance, compliance and IR practices. Prior to joining EQS her roles included heading up the IR Services at Capita Asset Services (now Link Asset Services) and being Managing Partner of a corporate governance and communications consultancy.