Tag: hotlines

Portugal and Ethics Hotlines

Under guidelines published by the Portuguese Data Protection Authority on the 1st October 2009, a whistleblower cannot make a report anonymously. I have to admit that I can’t read Portuguese, so reading Deliberação Nº 765 /2009 does not help me much in interpreting the limitations. (Google translate helps.)

Most EU member states allow anonymous reporting as a last resort. Portugal went a step further and outlawed anonymous reporting completely.

The Portugal guidelines also limit hotline use to reports of corruption, banking and financial crime and internal accounting controls. It’s not allowed for breaches of general codes of conduct. To go a step further, whistleblowers may only report against individuals in managerial positions.

If you are a public company with operations in Portugal and required to have whistleblower hotline under Sarbanes-Oxley, you need to look at these limitations. They seem to be in direct conflict.

Thanks to Bill Piwonka of EthicsPoint for letting me know about this. EthicsPoint supplies my company’s hotline.

Sources:

Best Practice Advice for Improving Employee Awareness of Your GRC Program

This post gathers my notes from a webinar entitled Best Practice Advice for Improving Employee Awareness of Your GRC Program which was presented by EthicsPoint.

Barbara Upton-Garvin from the Boys & Girls Club of Greater Kansas City started off with a discussion of their awareness programs. They highlighted their ethics policies and their whistleblower’s policy.

Francine Obregon of Eisai handed out schwag with the whistleblower hotline information. The awareness program was in part designed to advise the employees know that the hotline is part of a larger compliance program. They had recently changed the principles of corporate conduct. She thought it was important to let peopel know that the person answering the hotline would not be answering the questions. The hotline was merely an anonymous conduit.

Barry Elmore from the Majestic Star Casino wanted a program to educate their employees and marketing of the reporting process. They have a broad range of education and knowledge for their employees. They found that the education process was over the heads of many front line employees so they stuck to the basics. They also educated their vendors as part of the program. They conduct new hire training and annual training. They also advertise the hotline in employee break areas and employee newsletters. They sent a copy of the code of conduct to each vendor. Some of his challenges include the 24 hour operations of the business, lots of turnover and confusion between HR issues and code of conduct violations.

Francine pointed out that Eisai focused on branding issues so that all of the compliance materials and schwag all had a similar look and feel.

Barry emphasized that you cannot be boring in delivering the message and training. The examples need to be on the “lighter side.”

Julie Rivera of Red Robin put up posters and handed out wallet cards. “Honest ro Goodness. It’s not just about gourmet burgers. It’s about treating people respectfully.” Red Robin started out with a top-down approach of getting buy-in from corporate in its push out to the individual restaurants. There was some confusion between the open-door policy and hotline. They do get a fair number of low level HR issues on the hotline.

The panel had some trouble answering a question about the effectiveness of the awareness program. Barry and Barbara both see an increase in the number of reports shortly after a training session.