Ask a CCO: what is a good internal reporting system? | Item

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Q: What are the qualities of a good internal reporting system?

Meet the CCOs

PILAR CABALLERO

Vice President, Chief Compliance and Privacy Officer

Ryder System

Years of compliance: 20+

Keith carrington

KEITH CARRINGTON

Chief Compliance and Privacy Officer

North American Dental Group

Years of compliance: 20+

Jason cofield

JASON COFIELD

Chief Compliance Officer

Abiomed

Years of compliance: 6

Joel katz

JOEL KATZ

Vice-President, Assistant General Counsel and Director of Ethics and Compliance

Booz Allen Hamilton

Years of compliance: 12

Deena King

DEENA KING

Chief Compliance Officer

The University of Texas at Tyler

Years of compliance: 16

Michelle Ball Pendergrass

MICHELLE BALL PENDERGRASS

Chief Compliance Officer / Privacy Officer

Midland Health

Years of compliance: 25

Charles Schwager

CHARLES SCHWAGER

Vice-President, Chief Compliance and Ethics Officer

Waste Management

Years of compliance: 15+

DISCLAIMER: The opinions expressed by the practitioners cited are their own and do not represent the views of their companies.

PILAR CABALLERO: Three key data points that I review to make sure we have a great reporting system are frequency, substantiation rate, and corrective actions. A good system should be actively used by journalists. It shows that employees are engaged and trust the process. Likewise, a healthy substantiation rate indicates that the reports are of high quality and that the investigations are thorough. Finally, ensuring that appropriate corrective action is taken in each case where an allegation is substantiated demonstrates that reports are taken seriously and reinforces a culture of commitment to ethical conduct.

KEITH CARRINGTON: First of all, an internal reporting system should never be a “check the box” program in which a complaint is submitted but there is no evidence that the problem is resolved. An effective system offers several reporting channels: a hotline, direct access to the compliance officer and service, and proactive communication around the issue or the context of the complaint. By this I mean providing feedback and updates to your operational teams on the issues that have been raised and educating the necessary stakeholders on how to resolve them. Finally, ensuring that the organization has a non-retaliation policy and is aggressive in applying the policy is critical to the success of any reporting system.

JASON COFIELD: The qualities of an excellent internal reporting system are: accessible at any time and wherever the employee is; confidential and sometimes anonymous; available in local languages ​​with local toll-free numbers and easy-to-access websites; rapid response to journalists; and follow up with them once the case is over, if possible.

JOEL KATZ: Employees should clearly understand how they can report problems and generally understand what happens to the problem once they report it. Ongoing communication with employees during the duration of any investigation (and even after the investigation is completed), as well as a good measure of transparency (so that employees understand what the company has found and what the company has done about it), also go a long way in increasing employees’ belief in organizational justice.

DEENA KING: Third party. Anonymous. Sorted by a cross-functional group selected within 24 hours. The system has the ability to communicate anonymously with the registrant to ask questions and provide results. Our system has this last characteristic, and it is invaluable!

MICHELLE BALL PENDERGRASS: The first quality is awareness and training, as the workforce must have knowledge and understand how to report any problems. The second quality is that staff know that every report will be investigated and dealt with both fairly and consistently. The third quality is that staff understand that there will be no retaliation for internal reporting.

CHARLES SCHWAGER: A good internal reporting system must be flexible and adapted to the specific activity and risk profile of the company. The system should be documented, centralized and organized to track the lifecycle and details of all reported issues. The company must design the system to track problems, concerns and issues that are reported directly to the system and those identified by other departments. There should be processes in place to ensure that matters are handled in a timely, fair, efficient and confidential manner. Controls should also be in place to ensure that cases are properly investigated and that the appropriate penalties are assessed. In addition, the system should be able to generate reports that will allow full analysis of the data with key takeaways.


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