When Hellmann Worldwide Logistics was searching to upgrade its whistleblower hotline tool, Dominik Waszczynski knew who he’d like the new program to support most.
Waszczynski, the international freight and logistics company’s head of global compliance, began with the business’s warehouse employees in mind. From there, he would ultimately identify a straightforward tool the German company’s more than 13,000 employees across more than 160 countries could utilize.
As part of a Q&A with Compliance Week, Waszczynski explained the decision-making process that led to Hellmann’s whistleblower tool determination. His answers below have been edited for clarity and brevity.
Q. You’ve said Hellmann designs its compliance program with the end user in mind. How did you apply that philosophy to choosing a whistleblower hotline platform?
A. The whistleblower hotline is one of the most crucial parts of the compliance management system. If you use a tool the correct way, it can help to give you a detailed overview of your risk landscape. But you must absolutely depend on the people that bring up the information to you because if you don’t offer a good channel, you might run the risk people will decide not to contact you at all—neither in person nor via a dedicated electronic channel.
So, what we were thinking about was not a full, sophisticated, 125-language solution with a bunch of fields to click on. What we wanted was a solution that was intuitive; one where people could say, ‘I’m a little bit stressed because I want to talk about something that is not in order.’ The starting point would be a small window.
We also wanted to offer a solution (for a whistleblower) to come up to us directly or to report in an open way. If they wanted to report anonymously, maybe we would have some kind of mailbox system to simply drop a message? We wanted to consider many possibilities.
Q. What were your primary requirements for the whistleblower hotline software?
A. We wanted to configurate it in such a way that made it the most useful to our employees. … We were not interested in a huge supporting team, a machine behind a call center, or a system that needed many updates. We just wanted easy, straightforward tools. The best option would be a tool we could also use in other applications.
We used a product from BRYTER; what we liked was we could put it together as we liked. And they could give us support if we had some kind of hiccup down the road.
Q. Since the hotline was established, have you seen an increase in calls? What does that tell you about how it’s working?
A. This is exactly the question a compliance officer should ask before he or she decides to design such a program. The question should always be, ‘What does the number of tip offs or reports mean for me?’
A small number of reports could mean three things. First, you have the best and most compliant company in the whole wide world. Second, people simply aren’t telling you anything. Third, people are trying to report a problem, but they are not able to find the right way.
The best result you can get, from my perspective, is a large number of reports. Most of the reports are something like, ‘I don’t like my boss,’ or ‘I don’t like the window I’m looking out.’ But then you know people know about the hotline. They know how to use the hotline. They are not holding back. They are not thinking, ‘Oh, compliance will not listen to me.’ They come with everything.
Among all of that, there’s a small number of reports that are really concerning, and you follow up on them. After we implemented the [new tool], we saw a huge increase (in reports).
Q. I understand you might use this platform for other functions to manage Hellmann’s gift and hospitality policy. How will that work?
A. [The new tool] can be configured as we like. One arm is the whistleblower hotline, but the legal departments can use it, for example, for legal intake, reporting matters, and so on.
The gift and hospitality tool will be a great thing as well. We have an anti-bribery and gifts and hospitality policy that gives guidance to employees about what is appropriate and what is absolutely not appropriate. We have a tool where an employee could say, ‘This is what I’m intending to do, this is what I’m intending to receive. Just give me an idea, is this OK? Is this within company policy?’ And the tool could tell you it’s fine and give a green light. And when you have something else where we would say, ‘No, maybe we should talk about this,’ it directly links the person to the regional compliance officer.