We used to have lunch every week, but since I reported my concerns, my manager never asks me to join her.

When I walk into a room, the laughter stops. They must think I lost my sense of humor when I filed that report.

Getting information around here is like pulling teeth. Nobody tells me anything anymore.

Last week I made an excellent suggestion and my manager totally ignored it. She used to listen to me, but not now.

Most people would never intentionally retaliate against a co-worker who reported wrongdoing.  Both managers and employees know that reports help BBNC, and that even bad news can help us make improvements that are good for us in the long run.  But normal, human emotions can sometimes override our intellectual understanding, especially in difficult or uncomfortable situations.  Each of us needs to be very aware that our words and attitudes can send subtle signals that can feel as much like retaliation as more blatant acts.

Understanding Retaliation

There are forms of retaliation that we all recognize and know are wrong.  These include job loss, demotion, transfers, poor performance reviews without cause, low pay increases, and public attacks on the character of someone who has made a report.  This kind of retaliation is clearly against our company’s policy, and will not be tolerated.

Subtle Retaliation

But another, more subtle form of retaliation may happen when negative reports are made. What are signs of subtle retaliation? Perhaps even without realizing it:

-Information is withheld from the person who made the report — perhaps to keep him or her from pointing out something else that is wrong.

-The reporter is not included in social events.

-His or her suggestions are ignored.

-Co-workers and managers use body language to create distance, or allow anger to come out as sarcasm or jokes.

These actions send a powerful message and make employees reluctant to report problems.

No matter what you do for BBNC, your actions matter. It’s important to be aware of any subtle messages you may be sending whenever an issue is raised. Tone of voice and body language can convey even more than your words.  Looking away as a person approaches, sitting with arms folded, turning away from them in meetings, sending other people a disapproving look behind the person’s back — all of these may be interpreted as retaliation, which is against our company policy and may lead to negative consequences including fines or loss of your job.

Remember that your intention has nothing to do with how your actions are perceived. Although you might not intend to retaliate, the other person may perceive your words or actions that way.  Each of us must take steps to keep our own emotions in check and avoid the dangers of subtle retaliation.

Discussing the Issue

The best way to encourage reporting and prevent retaliation within our company is to begin the dialogue and discussion before there is a problem.  All employees are encouraged to discuss ethical issues with each other or with their supervisor.  If you can resolve issues within your own area, do so. If issues or concerns need to be escalated in order to be resolved, be responsible and call HR, the Compliance Team, the Ethics Hotline, or another company resource.

It’s normal to have some strong emotions when a difficult issue is raised. Don’t let them get the best of you! All employees should be able to discuss ethical or interpersonal issues in a way that addresses the problem and encourages communication. Here are some tips to remember when handling sensitive situations for both managers and employees.

-Keep the issue or concern on a confidential basis involving only those necessary to resolve it.

-Remind yourself that the goal is to resolve the problem, not to be “right” or to assign blame.

-Try to isolate the facts from rumor or speculation.

-Focus on the problem at hand. Don’t bring up the past or other issues that are not relevant to the current situation.

-Decide on the best and most workable outcome and agree on an action plan.

If you need assistance in resolving a problem, feel free to seek help from your manager or any other company resource, such as HR, the Compliance Team, Legal or the Ethics Hotline.

Reports and Investigations

Complaints are taken seriously at BBNC, and will be promptly and fully investigated.  Investigations are conducted by someone outside of your immediate area.  These experts are trained to investigate issues while maintaining as much confidentiality as possible.  Let them do their job.  Don’t try to find out more about who made the complaint or why, and don’t investigate the issue on your own.  If the investigators interview you, be sure to keep confidences.  Do not talk to others about the situation, including other employees or anyone outside the company.

BBNC provides multiple resources for every employee to report, clarify a situation, or ask a question.  Use these resources.

-Your supervisor or manager — these are the people that know you and your job circumstances the best. They can advise you specifically and immediately.

-Higher management in your business division welcomes you if you are not comfortable, for any reason, speaking with your own manager.

-Human Resources, the Compliance Team and the Ethics Hotline are all expert resources for you to clarify a concern, get information, or report suspected wrongdoing.


I just found out that one of my co-workers made a complaint. I want to know who it was because I think I can help resolve the problem.  Since I only want to help, can I ask the Compliance Team to give me this information?

No.  You should contact the Compliance Department and tell them what you know about the situation. However, Compliance is committed to preserving the confidentiality of the reporter in any way that does not impede the investigation. They will not provide this information to anyone who does not need to know it in order for the investigation to proceed.

During an investigation, one of my co-workers retaliated against the person who made the complaint.  If the person files retaliation charges, who may be held responsible for this behavior?

The person who retaliated, his or her manager, and our company may all be held liable.  All employees must understand BBNC’s non-retaliation policies.  If there is a retaliation claim, both the manager and the retaliating employee may be subject to fines or disciplinary measures.  If you are aware of possible retaliation, you should call the Compliance Department or the Ethics Hotline with the information that you know.

I made a report a few months ago.  The issue was resolved, but I just had my performance review and my manager made a number of suggestions for improvement.  I feel singled out.  What can I do?

Performance reviews should be honest assessments of your performance and may legitimately include suggestions for improvement.  Consider your manager’s suggestions in this light, and don’t assume they’re a result of your earlier report.  If you feel that your performance evaluation was unfair, speak to the Compliance Team or to HR.

I have had issues with one of my co-workers.  Since I talked to my supervisor about the situation, my co-worker seems distant and cool with me and others in our area.  What can I do?

Try your best to model excellent behavior by not reacting to your co-worker’s cold shoulder. Involve everyone equally and be a good team member.  Hopefully, your example will lead the way for all of your co-workers.  If any attitude over your report becomes an issue for work performance, bring it to your supervisor’s attention (or to HR) so that he or she can resolve it