Hot off the Press! New Best Practice for Speak Up and Investigations


By Kristy Grant-Hart, CEO, Spark Compliance Consulting

There’s a new best practice for speak up and investigations that has it all. It will make your data set fuller. It will give you more insight into trends and problem areas. It will help you to see the effectiveness of your Speak Up program, especially when it comes to managers. Sound good? It is!

This tip comes from the SCCE’s fearless CEO, Gerry Zack in his column in Compliance and Ethics Professional Magazine. I liked the idea so much that I decided to expand on it, including information on which metrics to track and how to implement a tracking system.

So what’s the new best practice?

Ask this Question

When you’re receiving a concern, ask whether this is the first time the person has raised the issue, or if they tried to raise it before. If the answer is yes, they did try to report it previously, follow up with them to find out what happened.

Why this Information is Important

Learning whether someone reported (or tried to report previously) is critical information. Let’s say you just received a report via Speak Up that Sally alleges that her co-worker Nigel is harassing her. Unless you ask, you’ll probably assume that this is the first time Sally has raised the issue.

If you ask Sally whether she’s previously reported it and she tells you that she raised it to her manager, that may identify a bad manager or a manager who needs more training. It may also indicate that Sally has a manager who makes excuses for their team members rather than enforce consequences for bad behavior.

If Sally states that she thought about reporting previously, but didn’t, find out why. Was she afraid of retaliation? Did she think nothing would be done? Keep track of this information as well.

Making Metrics and Dashboards for Insights

Once you start tracking this information, you can create fascinating dashboards and metrics. Track the percentage of people who tried to report previously versus initial reports. Ideally, you would have 100% initial reports. If you’re not at 100%, take heart. Knowledge is power, so tracking this percentage will help you to address the problems.

You can produce metrics relating to where people tried to report first. This may include their manager, other leader, HR representatives, legal representatives or other compliance officers (heaven forbid!).

Additionally, keep track of the responses of those who tell you that they previously thought about reporting but didn’t, and the reasons why.

After investigations, review substantiation rates and severity of disciplinary actions. Were the reports made a second or third time more likely to be substantiated than initial reports? Were the disciplinary actions more severe for these reports that were made multiple times?

Find Trends Over Time

Track the information over time to see trends. Cross track this data with other measurements, such as statistics from your Ethics and Culture Survey or Engagement Survey results. All of this information will give you great insight as to how culture is moving at your company.

How to Do It

If you have an online case management system, call your customer service representative and ask them if you can add a new question or field to your intake form. Make the field mandatory so you’re getting the full picture.

If you’re tracking your cases manually via Excel or other program, add a row or column to capture the information.

Data is Powerful

Understanding reporting at your company is critical to comprehending culture. Thoughtfully used data is the best way to gain insight into your employees’ experiences. What are you waiting for? Get tracking.