Corruption Matters - November 2019 | Issue 54
Whistling While They Work 2
New research findings highlight three essentials to effective design and implementation of internal reporting systems: (1) ensuring the first response to a report of wrongdoing is the right one, (2) creating a supportive reporting environment, and (3) assigning clear and effective roles and responsibilities.
Clean as a whistle: a five step guide to better whistleblowing policy and practice in business and government presents key findings and actions flowing from the Whistling While They Work 2 (WWTW2) research.
WWTW2 is a project supported by 22 partner organisations, including the NSW Ombudsman. It draws on data from 699 organisations, and the experiences of 17,778 individuals in 46 public and private bodies.
Key findings
Whistleblowing is a critical avenue for organisations to detect wrongdoing
The research again confirms the importance of whistleblowing: internal employee reports are the single most important method by which wrongdoing is brought to light. They are ranked more highly than internal audits and routine controls. According to managers, the majority of internal employee reports have also resulted in positive or necessary organisational change.
Most whistleblowing occurs alongside other personal or workplace issues, and this raises additional challenges
More than half of public interest wrongdoing reports are “mixed reports” that involve public interest wrongdoing and some element of personal or workplace grievance or issue. New approaches are needed to meet the challenge of triaging mixed reports to ensure that the public interest wrongdoing components are addressed effectively and reporters are protected. This may require, for example, the formation of a joint assessment and case management panel comprised of different functional areas.
Often the whistleblowing component in mixed reports is overlooked or mishandled. Managers said that such mixed reports were more likely to involve staff with a history of pre-existing disputes, and they
- were less competently investigated
- were handled in a less procedurally fair way
- took longer to resolve
- resulted in reporters being treated worse.
Organisations must proactively manage the risk of reporter mistreatment
Important risk factors associated with reporter mistreatment were:
- the seniority and number of alleged wrongdoers (the more senior and the greater the number of wrongdoers, the more likely the reporter mistreatment)
- the extent that the reporter’s identity remained confidential (keeping the reporter’s identify confidential, where possible, was a key means of reducing the risk of reprisal).
Crucially, the evidence also reveals that reporters are treated better by both management and colleagues and face fewer repercussions if organisations:
- assess the risks of conflicts or problems arising when a report is made
- intervene early to minimise risks
- provide proactive support.
It is particularly important for organisations to be alert for informal, “collateral” impacts, such as stress, impacted performance and isolation, in addition to deliberate reprisals and employment actions.
Leadership, culture and training are essential
Leadership and a cultural reinforcement of ethical behaviour underpin an environment in which appropriate support is provided and good investigation outcomes are achieved. This includes appropriately resourcing and training an independent, specialist internal function to coordinate the internal reporting process, from assessment to remediation.
For advice on implementing an internal reporting system, see the NSW Ombudsman’s public interest disclosure guidelines or contact us at pid@ombo.nsw.gov.au.