Our business sense tells us that ‘experience’ is a valuable commodity when making decisions. With misconduct reporting systems and processes there is rarely the existence of that embedded experience prior to establishing such a process. So when looking to set up your processes please bear in mind the following “Do’s & Dont’s”.
Marc Payne, former Business Practices Officer of Novartis and now owner of M-Consulting.
Do: Ensure that a clear communication on the misconduct reporting process has been sent out by the CEO supporting the policy and the rationale behind it.
Don’t: Regardless of the communication from the CEO, don’t assume that the process will be universally supported, it requires countless repetition, patience and above all tact when dealing with business units.
Do: Ensure that the process is supported by copious communication emails, flyers, posters and internet pages. There is never a case of too much exposure.
Don’t: Become the judge and jury for complaints. Establish a clearing house for reports, have them professionally investigated and then follow your current disciplinary process to review the investigation findings.
Do: Recognise that culturally your business is diverse and that complaints may flow from some parts better than others, embrace the diversity and do not penalise low reporting areas openly to senior management unless you know the facts.
Don’t: Spend the early part of the process analysing the outcomes or origins of cases or for that matter the perceived “root causes” of misconduct. Allow the process to be managed effectively first and then the analysis can begin.
Do: Hire the right people to review and interact with complainants, a third party company to handle initial reporting is the key to impartiality. Once the complaint has arrived, an appropriate review to determine next steps is crucial. Emotional intelligence, knowledge of the business and leadership are required in this role.
Don’t: Assume you can manage the process on a spreadsheet. Start your process with the knowledge that it will grow by 50% (in total complaints) from year one through year two. Keep appropriate records whilst ensuring Data Protection and Privacy issues are maintained.
Do: Make constant reviews and adjustments of the process dependent on your findings, regardless of whether they are in year one or year five, keep an open-mind about improvements and be flexible.
Don’t: Categorise initial complaints as “urgent” or “immediate action”, such labels will only come back to haunt you later if you have not acted as the labels suggest. All initial complaints should be handled the same, only when the investigation has begun and facts are known can you classify correctly and inform appropriate management should the need arise.
About Marc Payne:
Marc Payne is the principle consultant at ‘M’ Consulting a management service he started early in 2013. The key focus is to aid companies in their endeavours to manage and facilitate internal misconduct reporting programmes and processes. Marc has gained extensive experience through his prior occupation as Business Practices Officer for Novartis (a Swiss Healthcare Company).
He established the Global Business Practices Office (BPO) program for Novartis in 2005.
For more information please visit www.marcapayne.com