“Our company’s ethics and compliance program requires me to report any wrongdoing that I might observe.  So far I haven’t been put to the test, but just thinking about the possibility of ‘reporting’ something on the Ethics Hotline makes me feel uncomfortable.”

Have you had similar thoughts? Do you imagine that if the time came to report a wrongdoing that you have observed, you might be reluctant to report it?  It is common for employees to have second thoughts before reporting suspected or observed wrongdoings. In fact, surveys of worldwide employee groups in large companies have uncovered some common perceptions about reporting such incidents.  The reluctance seems to come from these perceptions:

-It’s disloyal to co-workers to report incidents of wrongdoing

-Fear of retribution or retaliation

-The belief that reporting wrongdoings won’t change anything

-Fear that the investigation will be made public

Let’s explore the reality behind these perceptions.

Misplaced Loyalties

Loyalty is a virtue, but how is it manifested?  Is it loyalty to the ship or the shipmates, to our company or to your co-workers?  You may believe that by protecting a fellow employee you are being a friend and a loyal co-worker. You may think if you don’t report your observation, your co-worker will work things out or not be found out. However, in most situations, the wrongdoing was not intentional. The sooner the error is reported, the quicker it can be resolved. You should also realize that if you have observed a situation that should be reported, chances are good that someone else has observed it too.

In the long run, your co-worker might benefit from you reporting the situation, or by reporting it him or herself. Reporting your observation to your supervisor or the Ethics Hotline will also help the organization maintain our reputation for compliance and ethics, which keeps business healthy.  A healthy business is a benefit to all employees.

Fear of Retribution

Our organization’s policies state clearly that any type of retribution for reports of wrongdoing are not tolerated.  The executive team encourages employees to report or ask questions and will enforce non-retribution polices to the fullest degree. No one needs to fear retribution for contacting the Ethics Hotline about any situation.

When a problem is observed, the best course of action is to create an open dialogue with co-workers, supervisors and management about any problem or situation. However, the Ethics Hotline provides an avenue for employees to speak up when dialogue is not possible. The anonymous nature of the Ethics Hotline creates a secure forum for employees who believe that they might otherwise not be fairly heard.  You should consider it a confidential and secure resource for you to ask questions and report your observations.

Nothing Will Change

Many surveyed employees felt that “the company has always done it this way” no matter what, and so they failed to make an effort to be heard. Often, situations that cost a company thousands of dollars may have been avoided if employees had used the Ethics Hotline for communication with management.

Be assured that calls to BBNC’s Ethics Hotline are taken very seriously. Situations are investigated and systemic problems are assigned to individuals or committees to be resolved within the organization. It may be true that organizational change sometimes takes a long time. But change will never happen without a stream of information and observations from employees who are committed to our organization’s success and ethical reputation.

Understanding the Investigation Process

Sometimes calls to theEthics Hotline simply require advice or a policy clarification. However, some reported observations or situations must be investigated. It is helpful if an employee who calls the Ethics Hotline is as specific as possible. In order to begin an investigation, the Compliance Team needs details about who is involved, what was said, or what reports should be examined. Keep in mind that if you do not identify yourself when you call the Ethics Hotline, you may also be investigated. All employees are required to cooperate fully in any investigation.

The investigating team will be made up of staff members appropriate for the reported situation. The team may include the Ethics Officer and perhaps Auditing, Human Resources, Legal or an outside agency. Team members will keep knowledge of the case as confidential as possible until the investigation is complete.

Generally, the results of an investigation cannot be public, even within the company or to the person who originally reported. There are very strict laws on defamation that could be invoked by individuals alleged responsible for wrongdoing if their situations were made known.

Use the Ethics Hotline

If you have a question or an observation, even if you are not sure that you have a dilemma, please call the Ethics Hotline. Usually calls are handled easily and the caller can be satisfied with a policy reference or advice. But occasionally, issues run deep or are complex. Though these cases may not be easy to resolve, they are the ones that are important to bring to the table. Communication within our organization is the key to our success now and in the future. The Ethics Hotline is but one tool for you to use in our continuing dialogue to improve our individual selves and our company.



Can I call the Ethics Hotline anonymously?

You can choose to remain anonymous when you contact the Ethics Hotline. However, there is no need to do so, since your identity will be kept as confidential as possible, and company policy protects you from reprisal or retribution. If you choose to remain anonymous you may also be subject to investigation yourself.

I have observed a situation that is against company policy. I know my supervisor sees it too, but chooses to ignore it.  Why should I call the Ethics Hotline when it’s clear that management doesn’t care?

If the situation is truly against policy, you have an obligation to report it. Your supervisor may not be as aware of the problem as you think. However, even if he or she is aware, the situation should still be reported and corrected. The Ethics Hotline exists to deal with this type of situation, so don’t hesitate to call.

When I see a situation that is wrong, isn’t it better to talk to my co-worker than to call the Ethics Hotline and “rat” on him?

You don’t have to call the Ethics Hotline if there is a way to resolve the situation through discussion or dialogue. However, you shouldn’t think of contacting the Ethics Hotline as “ratting” on your co-worker.  It exists so that situations, which can’t be resolved through discussion, can still be addressed.