(For related information about operating a Help or Hotline, see Hotline Operations)
In mandatory programs, the government expects “a process, such as a hotline, to receive complaints, and the adoption of procedures to protect the anonymity of complainants and to protect whistleblowers from retaliation” (DHHS OIG, Compliance Guidance). The Association of Certified Fraud Examiners has found that hotlines result in discovery of nearly three times more fraud than the next most effective means of discovery (management reviews and internal audits). But what if you have a hotline and no one calls?
Communicating effectively about your hotline involves answering upfront a series of questions:
One Hotline or more than one? Many organizations have one hotline and then “triage” what comes in to appropriate areas for follow-up. Others, like this medical center, advertise multiple hotlines, attempting to divert calls based on subject matter. Similarly, this county wanted to segregate calls about suspected child and elder abuse from those about “fraud, waste and abuse”.
Phone / Website / Email ? Even in 2012 many organizations have not yet moved to supplementing their 1-800-numbers with web portals. But those that have implemented websites often get at least as many reports through that route than the phone based “hotline”. For example, by 2009 Coca-Cola had more reports coming in through the web than via its phone line. However trained operators may elicit more information than a "caller" will type into a web report.
Who's the audience? Employees only? Whose employees? Adidas, for example, hires NGOs in China to run hotlines aimed at employees of its suppliers . Will calls from customers or the general public be welcome as at this hospital system or this bank? If customers aren’t to use the Hotline, where else should they be directed? This group purchasing organization encourages its suppliers to use its hotline as a formal grievance mechanism.
When should people call / use it? This may be the hardest communication challenge. Communication about the hotline is aimed at (1) creating awareness of this route for raising issues within the organization and (2) getting people to use it. The latter task requires overcoming user skepticism and fear of retaliation. Messaging ambivalence or hostility about use of the hotline in related communications, however, makes overcoming those sources of resistance less likely. For example, compare:
"The Hotline is to be used when other resolution channels have been ineffective or the caller wishes to remain anonymous" with
“Report fraud, theft, or other unethical conduct to the [Hotline]” and
“Be part of the solution. If you have questions, talk to someone. If you see conduct that violates our Code, report it!”
Each sends a very different “message” about the hotline. And getting this part of the "message" aligned with other aspects of the ethics and compliance effort is essential to receiving the calls the organization wants. For example, count how many times this Home Health Agency mentions its "Compliance Helpline" and for what types of matters, while describing its program.
What To Call It? Looking at the practices of others, the answer seems to be “just about anything”. Regulators seem to favor “Hotline” with its sense of urgency. Some multinationals have found translation of that term challenging. “Helpline” emphasizes that not every call needs to be about misconduct – but most will be, at least from the caller’s perspective. Here’s a collection of names and the organizations that chose them.
A large scale, cross industry study of hotline calls reported in 2007 found posters as the most frequently mentioned awareness source by far. Posters are frequently used and , in some cases, even required by various agencies. But in your environment maybe the most effective way to advertise the hotline is via your Inter and Intranet sites or by training managers on how to have conversations about it with those who report to them.
Certainly to encourage callers effective communication has to be ongoing after the initial roll-out. One frequently suggested strategy is sharing "stories" of calls and how they got addressed, as this Intel supplier does. Another is including information about the hotline in new employee orientation and other trainings.
(For related information about operating a Help or Hotline, see Hotline Operations)
In mandatory programs, the government expects “a process, such as a hotline, to receive complaints, and the adoption of procedures to protect the anonymity of complainants and to protect whistleblowers from retaliation” (DHHS OIG, Compliance
Guidance). The Association of Certified Fraud Examiners has found that hotlines result in discovery of nearly three times more fraud than the next most effective means of discovery (management reviews and internal audits). But what if you have a hotline and no one calls?
Communicating effectively about your hotline involves answering upfront a series of questions:
One Hotline or more than one? Many organizations have one hotline and then “triage” what comes in to appropriate areas for follow-up. Others, like this medical center, advertise multiple hotlines, attempting to divert calls based on subject matter. Similarly, this county wanted to segregate calls about suspected child and elder abuse from those about “fraud, waste and abuse”.
Phone / Website / Email ? Even in 2012 many organizations have not yet moved to supplementing their 1-800-numbers with web portals. But those that have implemented websites often get at least as many reports through that route than the phone based “hotline”. For example, by 2009 Coca-Cola had more reports coming in through the web than via its phone line. However trained operators may elicit more information than a "caller" will type into a web report.
Who's the audience? Employees only? Whose employees? Adidas, for example, hires NGOs in China to run hotlines aimed at employees of its suppliers . Will calls from customers or the general public be welcome as at this hospital system or this bank? If customers aren’t to use the Hotline, where else should they be directed? This group purchasing organization encourages its suppliers to use its hotline as a formal grievance mechanism.
When should people call / use it? This may be the hardest communication challenge. Communication about the hotline is aimed at (1) creating awareness of this route for raising issues within the organization and (2) getting people to use it. The latter task requires overcoming user skepticism and fear of retaliation. Messaging ambivalence or hostility about use of the hotline in related communications, however, makes overcoming those sources of resistance less likely. For example, compare:
"The Hotline is to be used when other resolution channels have been ineffective or the caller wishes to remain anonymous" with
“Report fraud, theft, or other unethical conduct to the [Hotline]” and
“Be part of the solution. If you have questions, talk to someone. If you see conduct that violates our Code, report it!”
Each sends a very different “message” about the hotline. And getting this part of the "message" aligned with other aspects of the ethics and compliance effort is essential to receiving the calls the organization wants. For example, count how many times this Home Health Agency mentions its "Compliance Helpline" and for what types of matters, while describing its program.
What To Call It? Looking at the practices of others, the answer seems to be “just about anything”. Regulators seem to favor “Hotline” with its sense of urgency. Some multinationals have found translation of that term challenging. “Helpline” emphasizes that not every call needs to be about misconduct – but most will be, at least from the caller’s perspective. Here’s a collection of names and the organizations that chose them.
Advice Line (Boston Scientific )
AlertLine (Milliken - phone only)
24 Hour Anonymous Hotline (Richmond University Medical Center)
Audit Committee/Whistleblower Hotline (election #2) and an Ethics Helpline (Selection #1) (Potlatch)
Awareline (Home Depot and General Motors)
Business Conduct and Ethics Hotline (Thomson Reuters)
Business Conduct Hotline (Microsoft)
Business Ethics Hotline (Adobe)
Business Ethics Line (Accenture)
Business Ethics Line: BEL and Compliance Hot Line: CHL (Yokogawa)
Business Integrity Line (Marriott)
Code of Conduct Line (Kimberly Clark - page 32, phone only)
Code of Ethics Line (Realogy Corporation - phone only)
Code Business Conduct Hotline (The Gap)
Code Reporting Hotline - 1-855-JPMCODE (JPMorgan)
Compliance / Compliance and Ethics Hotline (Kaiser "Help When You Need It" - Reportline on the web); (Columbia University Workplace Alert for web submissions); (Texas Reliability Entity); (University of Michigan)
Compliance Helpdesk (Siemens "Tell Us")
Compliance Helpline (Almost Family)
Compliance Hotline: 1-888-323-MCHTALK (Miami Children’s Hospital)
Compliance and Ethics Helpline - (650-721-COMP liance) (Stanford)
ComplianceLine (Hospital of Central Connecticut)
Comply Cats Hotline (University of Kentucky)
Concern Connection Line (American Red Cross)
ConcernLINE / ConcernNET (TE Connectivity)
Concerns Helpline (CenterPoint Energy)
Confidential Compliance Hotline (Memorial Sloan Kettering)
Confidential Ethics Hotline for Suppliers (Costco)
Corporate Compliance Hotline (Unity Healthcare - phone only)
Corporate Ethics and Legal Compliance Helpline (Toray International )
The Curo Integrity Helpline (Curo Health)
eDIALOG (UTC)
Employee Relations and Integrity Hotline (Target)
Ethics Line (Boeing - phone only); (Hospital Corporation of America - phone only)
Ethics Action Line (Tenet Healthcare - phone or email to : Ethics@tenethealth.com)
Ethics and Compliance Helpdesk (Premier)
Ethics and Compliance Hotline (Coca-Cola)
Ethics and Compliance Line (Intel - phone and email); (Alcoa - lots of numbers, reinforced with downloadable brochures)
Ethics and Compliance Services Helpline (DeVry)
Ethics and Compliance Webline (Starbucks - also has brochures)
Ethics and Financial Integrity Help Line (Eaton)
Ethics Helpline (Conoco Phillips);(Lockheed Martin - phone only);
Ethics Hot Line (The Mosaic Company)
Ethics Hotline at 1-866-4-Call-ME (Masco)
Ethics Line (800-760-4EEC) (SAIC)
Ethics OpenTalk (L'Oreal)
Ethicsline (Motorola)
Ethicslink (Staples )
EthicsOnline (Weyerhaeuser)
(866) ETHICSP (CMS Energy Corporation)
Ethos Line (Cemex)
The Fraud and Abuse Hotline (1-800-###-###) and The Privacy Hotline (1-888-####-####) (MD Anderson - phone only)
gCom Compliance and Ethics Phone Line (Genentech)
The GuideLine (CH2M Hill)
Help & Hotline (USC phone only)
Help Line (UPS - phone only - previously "conduct line"); (Kroger - phone only)
HIPAA Helpline - 1-877-HI-LOSS (NYU Langone Medical Center)
In Touch (previously Qivliq, now Akima)
Integrity Action Line (Schering Plough and Loblaw)
Integrity Helpline (Johnson Controls); (Nexen)(Harvard University)
Integrity Hotline (Oregon Health Sciences University); (Maxim Healthcare Services - phone only); (Encana)
Integrity Line (T-Mobile); (UCB)
IntegrityLine (Yahoo)
"Let Us Know" Compliance Helpdesk (Klockner & Co - web reporting only)
Open and Honest (Best Buy)
Openline (Northrup Grumman)
OpenTalk (BP)
215-P-COMPLY (U. of Pennsylvania ) (previously 1-888-ben-tips)
Protocol Helpline (Life Technologies)
Report It ! Hotline (Regions Financial Corporation)
Reporting Non-Compliance with Agency Policy and Procedures Hotline (Minnesota Housing)
Reportline (U Conn)
Safecall (Tullow Oil)
Speak Up Hotline (PepsiCo), Speak-UP! Hotline (Avamere)
Team Member Tipline (Whole Foods - phone only)
Think Again employee helpline (Marks and Spencer - phone only)
Trust Line ("Tell us, IT Matters") (Emory - phone only)
University / Medical Center Compliance Confidential 24 hour Hotline (Vanderbilt)
Vital Concern Center (Tyco)
VZ Ethics and EEO GuideLine (Verizon)
Ways To Report Concerns - 4 of them (Cox Health)
1-800-WE-COMPLY (Johns Hopkins)
Whistleblower Hotlines (multiple - University of California ; just one - Coloplast)
Wyntegrity Line (Wyndham)
1-855-YRVoice (Raise YRVoice) (AARP)
Government Operated Hotline Mechanisms
File a Form TCR "To Become a Whistleblower(Commodity Futures Trading Commission)
1-800-HHS-TIPS (1-800-447-8477) (US Dept. Health and Human Services Office of Inspector General)
Whistleblower - Informant Awards (Internal Revenue Service - since 1867)
OIG Hotline (US Dept. of Labor)
The Whistleblower Protection Program (OSHA)
Tip, Complaint or Referral Portal (Securities and Exchange Commission, Office of the Whistleblower)
How to advertise / promote awareness?
A large scale, cross industry study of hotline calls reported in 2007 found posters as the most frequently mentioned awareness source by far. Posters are frequently used and , in some cases, even required by various agencies. But in your environment maybe the most effective way to advertise the hotline is via your Inter and Intranet sites or by training managers on how to have conversations about it with those who report to them.
Georgia Health Sciences University has shared the roll-out and marketing plan for its Hotline.
Certainly to encourage callers effective communication has to be ongoing after the initial roll-out. One frequently suggested strategy is sharing "stories" of calls and how they got addressed, as this Intel supplier does. Another is including information about the hotline in new employee orientation and other trainings.
See also: Operating a Hotline