Hotline Call Follow-Up: Building Trust Through Effective Communication
Let’s talk about [Compliance] investigations...A call comes through a hotline - now what?
Is the Hotline managed via the Legal or Compliance Department or Human Resources?
Who will be tasked with looking into a complaint? Is the assignment process automated? And reviewed periodically. These questions must be considered, and a process or plan must be implemented.
Companies use internal resources for many investigations: sometimes, they use Human Resources personnel and other times, they use Legal/Compliance, IT, or Internal Audit departments.
Some departments are better equipped with internal processes for investigation then others; over the next few posts, I will discuss the different best practices for internal investigations and the hotline call management. Below please find Tip Number 1.
Tip Number 1.
Have a process for what happens when a call/inquiry comes in via 3rd third-party hotline provider. Understand the setup process of the hotline provider, for example, are calls/inquiries routed to specific people depending on the Organization/Department/Location/type via email for notification purposes and oversight. Is it clear who will begin answering the inquiry? Is this information reviewed periodically?
What is the assigning process?
Once assigned does the investigator understands timelines and expectations?
Below is a sample process of how each call/question/inquiry received on the Ethics Hotline should be managed:
KNOWN CALLER
INITIAL RESPONSE: It is recommended that each inquiry be answered within 24-48 hours with a sample note: “Thank you for contacting the Ethics Hotline, we appreciate your reaching out. My name is ________, and you can reach me directly at _________. I will investigate your concern and follow up with you at the phone number you provided to discuss this matter further.”
ONGOING INVESTIGATION
If you have ongoing communication with the caller, posting a monthly update to the online portal is recommended.
INVESTIGATION COMPLETE, CLOSING PROCESS
When; the investigation is completed, the investigator, with guidance from Legal, should post the final and closing remarks. Sample note: “We have completed our investigation regarding your concern. Our findings indicate [provide a brief summary of findings, if appropriate]. If you have any further questions or need additional assistance, please don’t hesitate to reach out.”
In consultation with the Legal Department, the caller should also be informed of the outcome of the investigation. Then the matter should be closed.”
ANONYMOUS CALLER:
INITIAL RESPONSE - Initial acknowledgments within 24-48 hours of receipt of the notification, sample notification that can be modified based on each complaint: "Thank you for contacting the Ethics Hotline, we appreciate your reaching out. My name is ________, and you can reach me directly at _________. I will investigate your concern. To better understand your complaint, please provide me with some details regarding your concern. Specifically, I would like to know the nature of your inquiry, the individuals involved, and any relevant dates or events.”
ONGOING INVESTIGATION
It is suggested that an update is posted on the Hotline Portal every two weeks or at least once per month; sample note: "The investigation is currently ongoing, please check back after (give two weeks date) for additional update. If you have any additional information please provide it to us, thank you." or “We appreciate your patience as we look into this matter. We are currently gathering information and will provide you with an update by [insert specific date].”
INVESTIGATION COMPLETE, CLOSING PROCESS
When the investigation is completed, the investigator, with guidance from Legal, should post the final and closing remarks. Sample Note: “We have completed our investigation regarding your concern. Our findings indicate [provide a brief summary of findings, if appropriate]. If you have any further questions or need additional assistance, please don’t hesitate to reach out.”
Having a process and sample language is essential, but ensuring that all employees involved in the administration and investigation of the Hotline [calls] are appropriately trained on this process is equally important.
