Executive Summary. This year’s analysis of our data from more than more than 4,600 hotline and case management participating clients revealed several key points ethics and compliance professionals can use to benchmark and assess their program’s performance, and move toward predictive risk mitigation. Of particular note in the 2014 data:
The five-year trend of rising report volume continues.
The increase year-over-year may not look major, but the 2014 median of 1.3 is a 44 percent increase in Report Volume per 100 Employees from 2010. This trend is likely the result of increasing maturation of E&C programs—as well as additional awareness of whistleblower cases and protections. Overall, it’s a promising sign that E&C programs are moving in the right direction: encouraging employees to report misconduct internally so it can be investigated and addressed.
Case Closure Times continue to climb.
From a median of 36 days in 2013 to 39 days in 2014, Case Closure Times continue to creep up. This is an issue for multiple reasons; two of the most significant are the erosion of employee trust as time passes with no action on a report, and the threat of getting too close to the waiting period for reporting to external regulatory bodies. Organizations should take this as a warning sign to ensure there are sufficient resources to keep Case Closure Times under control.
Low rate of anonymous reporters who follow up with their initial report still worryingly low.
With a 33 percent median for 2014, this data point is higher than it’s been since we started our report. (The median was 31 percent in 2013 and 30 percent in 2012). However, the relatively flat data point indicates that organizations have work to do to communicate the responsibilities of anonymous reporting. Namely, employees must be trained on the critical need to follow up with their own report and cooperate with investigators (anonymously if they choose to remain so) to ensure a full investigation of any allegation.
Substantiation Rates hold some interesting trends:
≫Substantiation Rates for Reports of Retaliation jumped from a consistent 10-12 percent to 27 percent. If this number is not an anomaly and continues to increase, it will soon approach the 40 percent Substantiation Rate (which remained the same for 2013 and 2014) for cases overall. This significant increase is, hopefully, a sign that E&C programs are taking a more serious approach to managing and investigating allegations of retaliation.
≫ Substantiation Rates for Repeat Reporters are higher than rates for First Time Reporters. Repeat Reporters have a Substantiation Rate of 42 percent; First Time Reporters’ rate is 38 percent. Compliance professionals need to continue to be careful not to let bias against Repeat Reporters affect their investigation of allegations made by this group. As the Substantiation Rate reflects, Repeat Reporters’allegations have a significant probability of being substantiated.
Allegations vs. inquires—a new data point to watch.
After fielding multiple requests for this metric from clients, we pulled data from the past five years to determine what percentage of reports made were allegations vs. inquiries. Our database reveals a fairly steady split of roughly 80/20 percent, with allegations being more prevalent than inquiries. Companies whose ratio is significantly different in favor of allegations may want to consider boosting awareness of their hotline as a helpline that employees can use to request ethics and compliance information and guidance—not just report misconduct.
As E&C programs continue to mature, these data points can be part of an organization’s overall scorecard to ensure they are effectively defining and implementing program initiatives—as well as moving toward the ultimate goal of taking proactive, rather than reactive, actions to help strengthen their organization’s culture of ethics and respect.
“Report Volume per 100 Employees is a volume metric that enables organizations of all sizes to compare their total number of unique contacts from all reporting channels (hotline, web forms, fax, email, direct mail, open-door conversations, manager submittals and more).
HOW TO CALCULATE: Take the total number of unique contacts from all reporting channels (incident reports, allegations and specific policy inquiry questions) received during the period, divide that number by the number of employees in your organization and multiply it by 100.”
“Substantiation Rate is a metric that reflects the rate of allegations made which were determined to have at least some merit (substantiated or partially substantiated). A high Substantiation Rate is reflective of a well-informed employee base making high-quality reports coupled with high-quality investigations processes.
HOW TO CALCULATE: Divide the number of overall reports that are (fully or partially) substantiated”