On 3 March 2016 Ethics and Compliance Switzerland held its first annual General Meeting of Members in Zurich followed by a presentation and panel discussion on the topic of “speak-up culture”. Gabe Shawn Varges, ECS board member, moderated the event and kicked-off by outlining various means by which companies are working to stimulate an internal culture of openness, where discussion on risk and ethical issues is not only tolerated but encouraged. One means of encouraging those who have a concern to raise it are channels of communication alternative to traditional hierarchy, including dedicated mechanisms that allow also for at least confidential or, if technically provided for, anonymous communication. Dominique Casutt and Fabienne Sonderegger followed by presenting the findings of the ECS guideline on the “Key Success Factors for Implementing an Internal Speak-Up Procedure”. They emphasized that whistleblowing such reporting lines support a speak-up culture if properly conceived and operated. They listed key success factors, including:
1. Sponsorship and commitment from the Board and top management as well as from other relevant stakeholders.
2. Management of expectations, regulatory requirements, cultural factors and resources and embedment of reporting procedure into general Compliance Management efforts.
3. Effectiveness of reporting and investigation procedures in terms of functionality, awareness (“communication and training”), associated roles and responsibilities (“ownership”), transparency, fairness and professionalism, including adequate protective as well as corrective measures and continuous monitoring and improvement.
Laurie Waddy, Head of Group Compliance at Lafarge-Holcim, followed by describing the big picture challenges of a chief compliance officer, including the cultural elements in the context of two large companies from different countries merging. She emphasized the need to see things from different angles and working with other functions.
The session ended with an animated roundtable discussion. Touched on were subjects such as national legal considerations for implementing whistleblowing lines, how likely employees are to use or misuse such lines, the importance of properly communicating on the existence and purpose of whistleblowing lines, and the use of various types of technology for reporting.