The symbol of Venice is the Lion of St. Mark. The use of this symbol led to the maxim ‘straight from the lion’s mouth’. This adage came about because the Republic of Venice had its own hotline system where citizens could report misconduct. A citizen could write down his concern on paper and literally put the message into the mouth of statues of lion heads placed around the City. This system was originally set up to be anonymous but later changed to require that a citizen had to write his name down when submitting a message.
I thought about this early form of hotline and how its use portended the hotline systems used today to help companies identify compliance issues which might arise under an anti-corruption law such as the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act. Obviously the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) recognize the importance of an internal company reporting system, such as a hotline. In the FCPA Guidance it states, “An effective compliance program should include a mechanism for an organization’s employees and others to report suspected or actual misconduct or violations of the company’s policies on a confidential basis and without fear of retaliation. Companies may employ, for example, anonymous hotlines or ombudsmen.” I have often heard Chief Compliance Officers (CCOs) speak about how they are able to not only hear about but address employee’s concerns through confidential reporting where it is clear there will be no tolerance for retaliation.
So, once again, using Venice as inspiration for a compliance topic, today I would like to review some best practices regarding a compliance hotline.The hotline should be developed and maintained externally. It seems axiomatic that employees tend to trust hotlines maintained by third parties more than they do internally maintained systems ...Zum vollständigen Artikel