Attention ethics and compliance officers: Employees of Fortune 500 companies now have an easier way to report sexual misconduct, ethical violations, and fraud, thanks to a newly published online directory.
The directory, compiled by I’m With Them —a nonprofit whose sole mission is to reduce work-related sexual misconduct—is populated with the anonymous reporting hotline phone numbers and Websites, e-mail addresses, chief human resources officers’ names, diversity and inclusion officers’ names, and links to the Codes of Conduct for approximately 160 of the largest U.S. companies across all industries.
Join the Compliance Week community
Receive the latest in corporate governance, risk, and compliance news from Compliance Week. Become a new member and get a one-year print & digital subscription for just $8/week.
Apple, Amazon, AmerisourceBergen, Berkshire Hathaway, Costco, CVS Health, Ford, General Motors, The Home Depot, Microsoft, UnitedHealth Group, Walmart, and Wells Fargo are just a few of the companies in the directory.
The Sarbanes-Oxley Act requires companies have an anonymous system for reporting ethics violations to their audit committee. While most companies choose to implement an anonymous phone line through which complaints are compiled into reports and then routed to the committee, “a company’s reporting channels and its Code of Conduct and policies can be surprisingly hard to find,” I’m With Them said.
“What should an employee do when confronted with a powerful executive violating the company’s code of ethics? Or when they feel they can’t trust their immediate management and HR representatives?” asked I’m With Them President Laurie Girand. “Where should a person who is harassed in an interview or audition file a report? This directory provides channels for reaching those with the power to take action.”
Research conducted by I’m With Them found just how challenging it is to identify this information. These barriers are particularly prevalent in the tech industry, where hotline numbers among many of the companies—like Apple and Amazon—“were not readily available via Google search,” the research found.
Many barriers make it particularly difficult for affiliates—those not employed directly, such as contractors, interviewees, and vendors—to notify a company of bad actors in its midst. “We are surprised the SEC doesn’t provide a directory like this,” Girand said.
In its report, I’m With Them offered 10 tips for companies to improve their ethics and compliance practices for helping employees report misconduct:
- The 1-800, anonymous reporting hotline should be the first search result for any search involving the company’s name and the terms “sexual harassment,” “sexual misconduct,” “sexual assault,” or “anonymous hotline.” The cost for paid advertising to achieve this goal would be minimal in comparison with downstream costs associated with ignorance of a brewing problem.
- The hotline should be called a “hotline,” not an “Ethics Line,” a “Compliance Line,” or a “Help Center.” Euphemisms obscure a hotline’s function, generate mispositioning that discourages reporting, and render searches ineffective.
- The hotline should be clearly described as an avenue for reporting sexual misconduct.
- The hotline should be accessible to non-employees, even if the Sarbanes-Oxley Act doesn’t require it.
- Wherever the word “hotline” is used, the word “anonymous” should precede it and the number should follow it.
- Companies should have a second mechanism, such as a Website or e-mail address, besides the phone line that enables reporters to upload documents and files.
- Tone from the top (i.e. the public messages of top executives), as well as in search results, should be welcoming and encouraging of reports.
- Companies should minimize governance jargon, such as the word “compliance,” which sounds intimidating.
- Where reporting is described in detail, companies should give generic examples of positive resolutions, i.e. “success stories,” to sexual misconduct reporting. The vacuum of information caused by confidentiality agreements in settlements and from employment law restrictions suggests positive outcomes don’t exist.
- Intimidating messages such as “Would my conduct be legal?” and “Would I be embarrassed if I reported?” should be eliminated.
The directory is not limited to the Fortune 500. Any company wishing to ensure its information is made easily accessible to those who would report misconduct may be included by contacting I’m With Them at email@example.com.
In addition to the directory, I’m With Them provides additional resources and services to catalyze workplace misconduct reporting, including an evaluation of barriers to reporting mechanisms and recommendations for overcoming them.