Why Ethical Lines Should Be Digital

January 16, 2024

Confidentiality.

In the last part of the previous article, we talked about having suitable means to report. The primary concern for whistleblowers, especially when reporting alleged irregularities by their superiors, is the possibility of facing retaliation. Retaliation can range from job loss to physical harm to oneself or loved ones.

Therefore, mechanisms for making reports must guarantee to the whistleblower that their comments will not reach the involved parties. For this reason, whistleblowers are skeptical of mechanisms such as telephone hotlines, where their voices can be recognized, or email addresses that can reveal the sender's IP address.

A digital application allows reports to be entirely anonymous if the whistleblower wishes, and, even better, that anonymity does not block further communication with the investigator assigned to each case. In fact, the whistleblower and investigator will communicate based on a case number assigned to each report by the application, and they can contact each other. The investigator may request additional information from the whistleblower, and the whistleblower can provide it or inquire about the progress of the report they submitted.

Immediate Data Contribution and Ensured Data Accuracy.

In an analog reporting mechanism, such as a telephone hotline, the person receiving the report must enter the data into an application. In this process, information can be misinterpreted or omitted.

In contrast, in a digital reporting mechanism, all data communicated enters the database immediately, and the whistleblower can be sure that the application has the exact information they provided and that it has been promptly sent to the attention of an investigator.

Additionally, in a digital reporting mechanism, the whistleblower can easily and immediately attach supporting documentation to their report, such as videos, photos, audios, and documents. The investigator may also inquire later if the whistleblower can provide such data.

Statistical Analysis and Trend Analysis

Digital reporting lines feed databases that allow for further data mining, enabling more efficient management of the mechanism. This allows the administrator of the reporting line to prioritize investigations and remediation actions based on trends observed in the reported cases. Consequently, areas, processes, or individuals that are subject to a higher number of reports will receive priority in investigations and remediation actions, such as procedure improvements, increased supervision, or audits

Additionally, this information will enable the reporting line administrator to allocate more resources to the investigative team to analyze and resolve cases as quickly as possible

Report Follow-Up by Whistleblowers and Communication Between Whistleblowers and Investigators

Reporting is the beginning of a process. After making a report, whistleblowers may initially feel relieved, but it is also possible that shortly afterward, they realize they need to provide new data or correct certain information they provided. In this case, a digital reporting line allows for immediate and anonymous communication with the assigned investigator, who can be contacted by referring only to the report number. There is no need to reveal one's identity if they choose not to.

Conversely, the investigator, in the course of their work, may need to validate certain data with the whistleblower or inquire if the whistleblower can provide new information to proceed with the investigation.

In analog reporting lines, once the initial enthusiasm for reporting has faded, subsequent contact between the whistleblower and investigator can be hindered by bureaucratic barriers. Conversely, this is streamlined by a digitally implemented ethical or reporting line.

Conclusion

"Spiritual Lines" is a demand, sometimes a plea, we make when something is going wrong. However, "doing something" is not enough.

As the illustrious Leandro N. Alem, who was a deputy in Argentina, said: "I have never practiced the idea that in politics, you do what you can and not what you want. For me, there is a third formula that is the true one: in politics, as in everything else, you do what you must, and when what you can do is bad, you do nothing."

Implementing an ethical line "for show" can even be worse than doing nothing. It is our duty to do it with the best means at our disposal.

With SHOGUN Ethical Line, you can guarantee the whistleblower's anonymity, turning your ethical line into a valuable technological tool for your organization.

Author: Guillermo Casal
International consultant and trainer in fraud prevention and investigation and anti-money laundering. He is a Certified Public Accountant, holds a Master's degree in Economics and Administration, and has six international certifications

Guillermo Casal

Guillermo Casal   argentina

A professional with 40 years of experience in the fields of forensic and internal auditing. He graduated as a Certified Public Accountant (UBA - Argentina) and holds a Master's in Economics and Administration (ESEADE - Argentina). He possesses certifications including CFE (Certified Fraud Examiner), Certified Internal Auditor (CIA), and Certified Information Systems Auditor (CISA).

He established the forensic auditing practices at IFPC - IGI, a firm founded and chaired by Stephen P. Walker, a former special agent of the FBI, and at the Law Firm of Dr. Luis Moreno Ocampo, former prosecutor of the International Criminal Court in The Hague.

He has led three Internal Audit units in large companies in Argentina and served as the Executive Director of FLAI, the Latin American Federation of Internal Auditors.

He presided over the Institute of Internal Auditors of Argentina. He has acted as a consultant, fraud investigator, and speaker in various countries in Latin America, the United States, Spain, and Mozambique.

Regulatory compliance with SHOGUN ethical line

European Whistleblower Protection Directive

ISO 37301: Compliance Management System

ISO 37001: Anti-bribery management system

ISO 37002: Whistleblower Channel System

EU General Data Protection Regulation

Corporate Anti-Fraud program

COSO: Committee of Sponsoring Organizations of the Tradeway Commission

 

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