Ethics & Compliance Hotline

Benchmark Report

2021
Prepared by:



Sara Orrell Business Analyst

Matthew Keding Database & System Administrator

Jenelle Case Chief Compliance Officer

Table of Contents
Introduction .......................………………………………………..........................................….......................
3

How We Calculated Our Benchmark Metrics ……………...…………….…………..…..........

4

Executive Summary …………………………………………………………………………………………….......................

5

What is Compliance 3.0?…………………………………………………………………………………..………………………..

8


1. Average Reports per 100 Employees ………………………………………………….…….............. 
 9


2. Reporting Channel .………………………………………………………………………………………………….…..…......

11

The Effects of COVID 19……………………………………………………………………………………………………….……….

14

3. Issue Categories ..............................…………………………………….................……..........................

15


Abandonment Rate: The Silent Killer……..............……..............……..................…….............

18


4. Issue Days Open .................................……………………………………….......……............................... 
19


5. Issue Anonymity…………………………………………………………………………………………………...................... 
 22


Troubling Retaliation Trends………………………………………………………………………………………………….….

25


6. Issue Severity Level …………………………………………………………………………………………................... 
 27

7. Issue Validity (Substantiated / Unsubstantiated) .....……….......................... 
 31

Expanding Your Reach…............…............…............…............…............…............…...................

34

8. Issue Sequence (Original Calls / Follow-up Calls) ………………..................... 
35

9. Reporter Awareness ………………………………………………………………………………………........……......... 
38

10. Reporter Type …………………………………………………………………………………………….……....................... 40

Hotline 3.0………………………………………………………………………………………………………………………………………….……
42

Conclusion …………………………………………………………………………………………………………….……....................... 43

About ComplianceLine ………………………………………………………………………………………........................ 

 44




Making the world a better workplace 2

Introduction
The core of our efforts as Ethics and Compliance (E&C) professionals must be centered on ensuring a safe workplace and promoting a
strong ethical culture of honesty and integrity. This mandate was put to the test during 2020 as the Covid-19 pandemic ravaged our
workplaces around the world. E&C teams were under enormous pressure to keep their people safe during this challenging time, and
their intake channels served as a critical tool to hear concerns and communicate the right information to their workforces. Moreover,
these challenges underscored the need for effective, not just efficient, risk management and a redoubled focus on agile continuous
improvement.

Analyzing issue intake and case management performance is The only way to gain true confidence in your program’s
a critical step in continuous improvement for your E&C performance is through measurable, continous improvement.
program in general, and for the organizational culture you are Comparing your organization’s metrics to peer and market
driving in particular. There is always room for improvement trends through benchmark data review to drive the ongoing
regardless of how successful your current E&C efforts are.

development we all want to achieve.

This benchmark report is designed to cut through the noise With three years of anonymized customer data and 138,939
and help E&C leaders focus on actionable comparison points reports in the 2020 datasheet, we explored the following
to drive improvement. Comparing your performance to a metrics: Average Reports per 100 Employees, Reporting
broad set of results helps ensure that you’re:
Channel, Issue Categories, Issue Days Open, Issue
Anonymity, Issue Severity Level, Issue Validity (Substantiated
Generating suitable ROI your program
vs. Unsubstantiated), Issue Sequence (Original vs. Follow-up
Calls), Reporter Awareness, and Reporter Type.

Substantiating an appropriate proportion of your cases

Following up on cases quickly enough

Outsourced hotline reporting services are core to nearly
every professional intake program, so we aren't surprised to
Creating appropriate awareness around intake channels

see that hotline reporting is still the top reporting channel.

Driving a Speak Up culture that generates the positive Furthermore, it's been on the rise, particularly through
Covid-19 -- up from 58% in 2018 and 61% last year to 63% in
impact more developed programs generate

2020. If that growth is surprising, read on to learn why.

Sufficiently training your people and refreshing your

policies
Thank you for trusting us to help you make the world a better
workplace. We hope you find this benchmark report to be a
Maintaining a level of agility necessary to respond to useful tool for examining your E&C program by looking for
unforeseen risks

ways to improve your employees’ experience and your

organization’s performance .

Making the world a better workplace 3

 How We Calculated Our Benchmark Metrics

Our analysis includes data from organizations that generated the same basic steps applied to retain statistical accuracy
greater than 10 reports during each measurement period. (i.e., removing clients with less than 10 reports during the
The dataset used for this report contains 138,939 reports year), we postulate that the respective datasets have a similar
across approximately 1,100 organizations in 2020.

degree of aggregate and specific normalcy.

Throughout the report, you will see references to Throughout the report, we tend to use aggregated raw ratios
comparable “Traditional Comparison” standard values. (as opposed to averages of averages) and untrimmed data as
“Traditional Comparison” refers to the Navex Global 2021 Risk the basis for our reported benchmarks. We found this
& Compliance Hotline Benchmark Report1 and is presented approach paints a more conservative and authentic picture of
to show a comparison point to the range of performance data performance, preserves outliers, and doesn’t create
available.

unnecessary data smoothing. Additionally, for the most

important metrics with skewed datasets, the resulting mean
In statistical analysis, “statistical significance” is extremely, values were relatively more conservative than the related
well, significant. With bigger sample sizes, you’re less likely to medians.
get results that reflect randomness. While the Traditional
Comparison report contained a sample of 1,411,158 total
reports, approximately 10x our dataset, this size difference is
not statistically relevant at these population sizes. For example, “Reports per Employee”

Comparisons between the Traditional Comparison datasets dataset has a positive skew,

and ComplianceLine datasets are statistically valid.

with the median value less


than its mean value.

Considering the dataset sizes another way, a statistically

significant sample from a dataset the size of the Traditional
Comparison report (1,411,158) with a 99% confidence interval
and 1% error rate needs to contain 16,385 reports. Our dataset Assuming the purpose of benchmarking is to accurately
of 138,939 is 8.5x larger than that. Given that the two datasets measure performance and identify ways to improve,
both represent large pools of the same general activity (i.e., comparing your organization’s actual reporting rate per 100
intake results from ethics and compliance hotlines across a employees to the median rate of 1.5 reports, rather than the
large number of diverse customer organizations) and have average of 4.1 reports would be less conservative in all cases.

1
Penman, Carrie. “2021 Risk & Compliance Hotline Benchmark Report.” Navex Global, 2021.

Making the world a better workplace 4

Executive Summary
Results of the 2021 Benchmark Report are encouraging because they continue to validate that a process that puts “people at the
heart of compliance” generates superior results, especially amidst a pandemic and ensuing social and economic challenges. The
results also illustrate that there is no silver bullet for effective E&C. Each organization faced its own challenges during 2020, due to
their unique circumstances and constraints. However, they also show that it’s possible to make the world a better workplace
through a genuinely caring and a common sense approach to risk management. This is what Compliance 3.0 is based on, and what
serves as our framework to elevate and improve E&C.

Many of the strongest perrforming companies in this dataset use compliance and ethics strategically to create and reinforce
positive organizational cultures, leading to sustainable crowdsourced risk management and superior organizational performance.

1 Reporting rate increased from 4.0 to

4.1 aggregate reports per 100
employees across the sample in 2020

Your reporting rate is perhaps the most important single metric to measure
cultural health. Maintaining a single data repository for all report types from
all intake channels is an obvious best practice at this point, but with 6 of 10
(Traditional Comparison1 from 2020 instances of workplace wrongdoing going unreported,2 “more reports”
declined to 1.3)


 remains the greatest lever for driving cultural improvement.

During 2020, the increase in reports per 100 employees was driven primarily
by COVID-19 impact and subsequent social challenges which were top of
4.1 mind for much of the year, coupled with a general increase in pressure to
meet performance goals and meet/exceed expectations. An additional
factor is an increasingly vocal workforce, 75% of which will be Millennial/Gen
Zers within the next 5-10 years.

Comp. 1.3

Per the Ethics and Compliance Initiative (ECI), 84% of workers report
misconduct in organizations with the most effective compliance programs,
compared to only 33% in those with weak or non-existent ones.3 Driving a
Speak Up culture is a smart way to improve operational excellence across
your organization, as the most ethical companies continue to see
significantly better performance than their peers.

2Van der Meulen, Rob. “Gartner Says Just 41 Percent of Workplace Misconduct Is Reported.” Gartner, 2019.

3The Ethics & Compliance Initiative, 2021. The State of Ethics & Compliance In the Workplace. Global Business Ethics Survey Report.

Making the world a better workplace 5

2 Original issues as a percentage of
total reports increased slightly to 84%
in 2020

Original issues versus follow-up mix provides good insights into how
reporters are experiencing your reporting intake, the quality of your
investigation process, and how well your organization communicates back to
(Traditional Comparison is 67%) the workforce.

Higher follow-up rates can sometimes coincide with more complex issues,
but are often driven more directly by (and are highly correlated with) longer
84%
case closure time, lower case closure rate, and a general lack of
communication back to the workforce at large. E&C teams with good intake
processes that also prioritize communication back to reporters tend to see
Comp. 67% lower follow-up rates, even while working remotely.

3 Hotline remains the most

dominant intake avenue

at 70%, a modest increase from the

COVID-19 and the ensuing Work From Home (WFH) environment drove an
expected decline in in-office reporting, which shifted to an increase in more
hotline calls, as online reporting was relatively flat at approx 9%.

historical value of 63%


(Traditional Comparison is 31%) Reporters continue to prefer the hotline to report complex issues. While
we’ve seen a general increase in online reports over the last 5 years, the
increase in hotline shows that in most cases right now -- and especially in an
emergency -- reporters want to talk to another human being.

70%
An empathetic, conversational approach that is flexible and able to respond
to new day-to-day challenges reinforces the commitment to a strong
employee experience and a strong employer brand. It shows that your
organization respects their speaking up and is committed to providing intake
Comp. 31% channels that actually work. It also should provide better information to get
your E&C team started, which saves investigation and follow-up time down
the road.

Making the world a better workplace 6

 Case closure time averaged 25 days Case aging is a critical metric to assess the health of your program and
4 (Traditional Comparison 39 days) up 2 investigation process. Organizations that focus on building an authentically
days from last year, with 79% closed in ethical culture view intake as the start of a conversation, and they tend to
less than 30 days (Traditional place a relatively higher importance on driving down case closure time.
Comparison 23%), a 4% improvement Beginning with good, substantive information at the start of an investigation
over 2019

(vs. wasting time on a bunch of report rework), coupled with a commitment

to investigation process excellence helps to drive this factor down.

Generally, the lower the case closure time, the better; best practice remains
25 days
to aim for case closure times of less than 30 days. Organizations that can
both maintain consistently low case closure times and communicate results
back to reporters quickly reinforce their organization’s Speak Up culture in
Comp. 39 days meaningful ways. Failing to do so compromises credibility and leads to
perceived behavioral duplicity in the eyes of the workforce .

57% of all reports were substantiated Higher substantiation rates indicate that proper information is being gathered
5 (Traditional Comparison 41%), and
32% of reporters remained
during the initial intake (hotline, in-office, or online), and that reporters
understand the purpose of the intake process. Generally, lower anonymous
anonymous (Traditional Comparison rates are better, as it can indicate a relatively lower fear of retaliation.
58%), both down from 2019


 However, rates under 20% should cause concern, as that can indicate a lack
of trust in the overall process.

Significant drivers of the decline in issue substantiation from from 63% in

7%
5 2019 to 57% last year were the WFH environment and the COVID-19 impact.
There was a relatively higher proportion of “unsubstantiatable” calls as E&C
teams repurposed lines to manage through emergencies.

Comp. 41% The increase in the proportion of reporters willing to be identified is

interesting, as it coincided with a WFH environment that naturally led to
fewer in-office reports (where retaining anonymity is virtually impossible).

Organizations should monitor and analyze their Anonymity Rate closely for
indication of high or low employee trust. Up to 39% of employees say they
are not confident that their concerns will be addressed fairly,4 and up to 79%
have experienced retaliation after reporting.3

4Allvoices.co. 2021. State of Workplace Wrongdoing 2021.

Making the world a better workplace 7

What is Compliance 3.0?

Where we are today? Here E&C crowdsources risk management sustainably, with
strong, strategic relationships forged with other departments
Many E&C programs today are flat, stuck in Compliance 2.0 and champions.

(a.k.a., “Compliance as a cost center”). The to-do list never

ends, and there are never enough hands or time or dollars to Here, E&C is viewed as a trusted advisor responsible for
manage the latticework of processes, technologies, data, and driving an authentically ethical culture that resonates with the
vendors trequired to properly do all the things that need to workforce, releasing its magic and driving superior
be done.

operational results.

The excitement and satisfaction of standing up a program -- Here E&C programs don’t only “know what matters,” focusing
taking an organization from the Flinstones to the Jetsons -- their efforts and resources appropriately and where needed.
where the impact of your efforts is apparant, is often replaced They also have the right tools, partners, and information
with programs whose impact has stagnated, where it’s dialed-in (vs. a bunch of dashboards, pie charts, and lakes of
sometimes difficult to see a significant impact from efforts data), freeing up time and focus for the non-urgent, but
expended.

important, things that can really move the needle -- the

things a vendor can’t do.

Moving beyond the focus on defensibility of 1.0 (“Keep the

CEO out of jail and our name out of the papers”), past the
move toward technology-based solutions to drive efficiencies Where are we going?
of 2.0 (yay dashboards!), Compliance 3.0 ascends to a focus
on multi-faceted effectiveness across the organization.
The E&C Renaissance will be exciting to witness and be a
part of over the next 10 years as more and more programs
ascend, like so many of our peers already have.

What Happens at the 3.0 Level?

The key to accelerating the transition to 3.0 comes from
Here, E&C creates strategic impact by using the tools already reaching out and learning from those around us in the E&C
in place in new ways, driving the right behaviors in the community, reaching out across the silos that have been
organization’s human beings.
erected in our organizations to combine forces with other
departments, and reaching throughout our organizations to
build trust with the people we are entrusted with.

Making the world a better workplace 8

 1. Average Reports per 100 Employees

2020 Avg. Reports / 100 Employees

8
R e p o r t s / 1 0 0 E E S

6.62
6

4 3.81
3.05 3.26

2.14
2

Traditional Comparison

< 1,000 1,001-5,000 5,001-10,000 10,001-50,000

0 50,001+

E m p l o y e e C o u n t

The more your workforce speaks up, the better your This overall increase in reports per 100 employees was driven
oganization performs. So in E&C the more reports, the better. by a confluence of specific and general factors. Across the
More activity/reporting generally means fewer fines and board, employees were feeling tremendous pressure in 2020
material lawsuits.5

amid the COVID-19 pandemic and a challenging social

environment -- employees faced spefic pressure to hit
In 2020, reports per 100 employees across various company performance goals, always be available, maintain job
sizes with 10 or more reports showed averages between 2.1% security, and/or generate more revenue/minimize costs in
and 6.6%, with an aggregate average of approximately 4.1 the most challenging compliance environment in over a
(median reports in aggregate were 1.5 per 100 employees) decade.

up from 4.0 in 2019. Generally, reporting rate declines with

organization size, as larger organizations tend to have a These specific factors, coupled with an increasingly vocal
higher degree of policy standardization and on-demand workforce that cares about issues of integrity and injustice
guidance available, while smaller ones tend to rely more more than ever before (see Special Report: Troubling
heavily on the flexibility of competent intake channels. Retaliation Trends, page 25) contributed to the increased
reporting rate.

5Stubben, Stephen and Welch, Kyle, Evidence on the Use and Efficacy

of Internal Whistleblowing Systems (February 29, 2020).

Making the world a better workplace 9

Even during a year like 2020, a Speak Up If your company receives fewer or more issues than
benchmark averages, try to understand why. Be sure to
culture cannot be forced top-down upon isolate Covid-19 outlier impact on your numbers, but
your organization. It must rise up organically recognize that lower call volume is usually due to

if it is going to be truly authentic, and will

Fear of retaliation

always be rooted in trust.

Lack of belief that management care or will do anything
about concerns raised

2020 also saw E&C programs utilizing their existing reporting

channels in creative ways to more effectively deal with the Lack of awareness of reporting channels

crisis. This ranged from leveraging standard hotlines with Painful intake process (e.g., lack of empathetic intake,
specific directives about unique challenges and processes, to confusing web forms, long wait times)

spinning up new dedicated lines to better field concerned

employees’ questions about PPE and Covid-19 protocols. This Counterintuitively, higher call volumes almost always indicate
helped resource-strapped E&C teams focus on their internal a healthier employee base and relatively stronger Speak Up
pandemic-driven priorities while leaving their employees culture, which lead to higher employee engagement, lower
with uninterrupted access to their designated hotline. employee turnover, fewer fines/lawsuits, and higher overall
productivity and performance

Think About
Even during a year like 2020, a Speak Up culture cannot be How to Calculate
forced top-down upon your organization. It must rise up
organically if it is going to be truly authentic, and will always Run a report from your case management system

be rooted in trust.

that aggregates all your reports, then divide


by your effective number of employees over 

Drive higher reporting rates by increasing employee the year. This is your reporting rate. Multiply by 100

awareness (rotate posters, increase communications and to find your number of reports per 100 employees.
training, reinforce messaging throughout the year using
storytelling), simplifying and streamlining the reporting
process (minimize call abandonment rate, utilize AI on
Internet reporting), preserving the safety of reporters (hire
and promote whistleblowers), and follow up with reporters in
Reports per 100

Employees
= ( All Reports

Number of Employees
) 100

a timely manner.

Making the world a better workplace 10

 2. Reporting Channel per 100 Employees
Reports by Reporing Channel/ 100 Employees
4
2.43

60%
2.52
2.87
33%
63% 70%
Hotline
3
Reports/100EES

In-office/In-person
.37 10%Reports
43%
Online Report
2 Traditional
Comparison
1.2
1.12
1.1228%Reports

30% 28% Traditional Comparison

.57 .48 .5637%Reports
.19%
78
.40
1
.39 .36
.31
.37

10%
.54 .56

.36
.37 10%Reports
.44

11%
.59
10%
0 2018 2019 2020

The above graph shows original issues by intake channel for This intake method...
Represents issues documented

2018, 2019, and 2020. These are presented with the Hotline
By the 24/7 Help Center

Traditional Comparison, along with implied reports on a “Per In-Office / In-Person

By client organizations

100 Employee” basis to help provide scale.

Online Report
Online via web form, app, texting

Making the world a better workplace 11

 Reporting Channels are extremely important to evaluate on Over the last 3 years, we have seen considerable growth in
an ongoing basis. They help organizations monitor the hotline reporting, which was exacerbated last year due to the
effectiveness of intake methods, identify where additional pandemic, up from 58% just two years ago. This
resources may be needed, as well as where additional corresponded to a decline in in-office/in-person due to the
opportunities exist for improvement. This metric is most WFH shift in the sample, though “essential businesses” that
valuable when considered in the context of a volume-based remained mostly open during the heights of the pandemic
metric, such as total reports. For example, if your percentages saw less of a deterioration, if any, in this category.

match the benchmark but you only get 1 report / 100

employees, you likely need more volume on each channel.

However, the sustainability of this trend is interesting to

consider and there are several factors at play. The
While web reporting increased to 11% of total, the WFH pandemic/WFH is obvious, but isolating for that, the
impact on in-office/in-person drove this channel down to 19% generational transition that is underway is having some
in 2020, pushing more net volume to the hotline, which was influence on how intake channels are utilized and in what
up to 70% of original reports. This mix shift accompanied a proportions. See the section, “Troubling Retaliation Trends” on
general increase in reporting volume during the period.
page 25 of this report for a deeper discussion. While
increased hotline reporting can indicate growing
organizational trust, it is also reinforced by an increasingly
vocal workforce.

2019 vs 2020 Reporting Channel by Company Size

100% < 1,000 1,001-5,000 5,001-10,000 10,001-50,000 50,001+
66.77%
66.66% 65.39% 73.83% 74.16% 61.52% 60.27% 75.88% 74.55% 48.19% 72.68% Hotline
80%
In-office/

In-person
60% Online Report

48.26%
40% 28.24%
14.47% 25.36%
17.31%
13.08% 9.86% 14.65% 13.85%
20% 20.14% 13.12% 22.02%
24..72% 16.04% 13.10% 15.98% 13.12% 11.49% 9.47% 11.60%
3.55% 5.3%

0 2019 2020 2019 2020 2019 2020 2019 2020 2019 2020

Making the world a better workplace 12

Significantly lower proportional hotline reporting rates where to look for improvements. Your individual challenges,

(controlling for volume) can indicate:

constraints, and workforce composition are just some of the

factors influencing this metric.

A lack of trust in the hotlin e

A lack of belief in a safe cultur e

Painful intake process (e.g., long call queues, robotic Think About

intake/no empathy, cumbersome questions)

How can you increase the proportion of your reports through

the Hotline (in the context of your reporting rate)? Round

A fear of retaliation (which is on the rise)

table discussion with known callers to your hotline to obtain

feedback, or even simple surveys can provide useful insights

Anecdotally, new clients who transition from other providers
for the “why” behind changes in your reporting channel
often show the most meaningful shift in hotline reporting
results. Revisit your directives and general call process (test
percentage. This is rooted in a combination of factors, your line at various times -- how did that process feel?) to
including a redoubled focus on Speak Up culture due to the
ensure the “customer” experience is inline with your
improved awareness/push materials, and a significantly more
expectations and your organization’s standards.

human intake process (empathetic elicitation). Regardless of

the reason, the driver of report volume improvement tends to

Analyze your awareness campaigns to make sure messaging
come through the hotline.

and imagery are optimized. If you are in a WFH scenario, how

have you altered your awareness plan to account for the

When looking at your own data, compare the proportions of “new normal”? When were posters updated last? (Best

your different intake channels, as well as changes in absolute practice is 2-4 times per year) What is your awareness

values within channels over periods of time to get a better strategy and content schedule? How can you be sure people

understanding of how your program is working and to identify know how and where to report?

How to Calculate
# Cases by Intake Method
Generate your list of cases over the last year and code Reporting

=
each one based on the intake channel.

Channel Total Cases
Sum all cases by channel and divide each total by the

total number of cases.

M a k i n g t h e w o r l d a b e t t e r w o r k p l ac e 13
The Effects of COVID-19
The Global Pandemic
In 2020, we all experienced a truly unprecedented situation. There were also reports of employees experiencing
The COVID-19 global pandemic affected every aspect of our harassment and/or abuse via video meeting software (e.g.,
lives from how we work to how we conduct our days at home Zoom). Because these interactions were new to so many,
with our families. It also affected E&C programs within our some didn’t know how to best report them. Others weren’t
organizations. The largest impacts came from the following even sure they were correct in their assumptions and
drivers:
definitions, as harassment in this setting has not historically
been covered sufficiently in traditional training.

Lower employee count

Handling The Crisis
Uncertain economic environment
Tighter budgets, hiring/spending freezes As expected, E&C pros-- the unsung heroes of the pandemic
-- pivoted and took action behind the scenes to help keep
Lower attendance (increased WFH)
employees working, keep workforces safe and informed, and
Confusion over policies keep risks at bay. Many forward-thinking companies set up
Conflicts from COVID=19 impacts dedicated hotlines to specifically handle COVID-19 related
issues, questions, and reports. This showed their employees
Feelings of distress and added pressure (balancing kids, their commitment to taking the elevated risks we all faced
new office space, loneliness and burnout) seriously and showed E&C was part of the solution.

Heightened fears (health, death, economic)

2020 also saw an increase in the effective use of technology,
such as optimized webforms, check-ins, and employee
surveys to create operational efficiencies and leverage.

The WFH Impact

Another positive reaction we witnessed was improved and
The shift for a majority of the workforce to WFH created its creative awareness and communications plans executed
own set of unique challenges. There were fewer interactions successfully. Email blasts to the employee base, simple
between managers and direct reports, which created a videos, awareness materials in the form of magnets and
challenge to both cultural reinforcement (distance creating cards, as well as more focused follow-up/”closure”
distance) and the ability to Speak Up directly to a manager communications with reporters and the workforce in general
in-office. all netted success for E&C employee customers in 2020.

Making the world a better workplace 14

3. Issue Categories Hotline only
Key

Human Resources: HR, Diversity, and Workplace Respect (Discrimination, Harassment, Retaliation, Compensation)

40%
Business Quality: Patient Safety, Clean Food Prep,Customer Service

Management & Staffing: Staffing

Safety and Environment – Community Maintenance/ Environment, Housekeeping, Unsafe/Unhealthy Workspace


Privacy & Information Security: HIPAA, Security

32% 31.13% Financial: Resident Billing and collections, improper billing, inappropriate coding

External Integrity: Fraud, COI, Prefilled and Post filled documents/Improper Documentation, Forgery

Internal Ethics: Misuse, Misappropriation of Corporate Assets (Employee theft, Time Clock Abuse)

General Information: General Info, Request, Reroute, etc.

Other: All Other

24%
20.28%

16.17%
16%
12.54%

8.63%

8% 5.38%
2.43% 1.56%
.77% 1.10%
0 HR Business
Mgmt &
Safety & Privacy &
Financial External Internal
General
Other
Quality Staffing Environment Infosec Integrity Ethics Info

HR-related issues remained the top category at 31%, followed Business Quality reporting can provide clues into cultural
by Business Quality, which stayed relatively stable at health and employee ownership, as apathetic employees
approximately 20%. Given the nature of how ethics and tend to not care about quality and are less likely to Speak Up.
compliance hotlines are used, HR as the top category is no A rate of Business Quality that deteriorates significantly over
surprise, and we saw both a general decline in this category time could be an early indicator of disengagement leading to
(pandemic-driven) and corresponding specific increase in general underperformance.

reports for harassment and discrimination, especially during

the middle of the year (social challenges, US election).

Assuming static categories across your comparison period,

look for significant differencesin category split to identify the
We also broke out a new category this year (again, COVID-19 first places to look for root causes. You should be able to
driven), “Safety & Environment,” which came in at almost 10%. point, at least anecdotally, to reasons for shifts in categories.
This category was utilized by many clients to handle Also keep in mind that updating your high-level categories,
COVID-19 issues/questions. while important to do periodically, can make comparing to
prior periods difficult, so keep your category updates
infrequent and thoughtful.

Making the world a better workplace 15

 Top Issue Categories through all Intake Methods

100%
26.49% 28.85% 27.62% HR

80% Business Quality

22.91% 24.19%
23.54% Privacy & Infosec
60%
Management & Staffing
8.24%
8.76% 7.05%
40% Internal Ethics
12.74% 11.24%
12.31%
5.03% 4.13% 1.88% Other/General Info
20%
21.38% 24.88%
18.81%

0 2018 2019 2020

Note, however, that this statistic has the most noise due to Fear of retaliation is present to some degree even in the
the subjective nature of category names and groupings healthiest of cultures. See 5. Issue Anonymity for details of
across the sample, so at best it is useful to see general trends anonymous mix and impact. The third-party protection the
to compare to your own. Monitor and track your reports by hotline and online channels provide drives this increase and
catagory year-over-year to better understand strengths and helps overcome the underlying fear of retaliation that
weaknesses in your program. Above we identified top accompanies reporting management issues within the
categories reported across all intake channels for 2018, 2019, organization. According to ECI, 79% of American employees
and 2020. HR-related issues remain the top category in this experienced actual retaliation after speaking up.3
cut of the data across all years as well, again, followed by
Business Quality issues.

In previous years, we have underscored that reports The third-party protection the hotline and
regarding management concerns are significantly higher online channels provide helps overcome the
through the hotline than through other intake channels, such underlying fear of retaliation that
as in-person/in-office. The significant increase in
“Other/General Info,” which contains “Safety & Environment'' accompanies reporting management issues
is largely attributed to COVID-19-related issues, particularly at within the organization.
health care organizations.

Making the world a better workplace 16

Think About
How to Calculate
What can you do to increase the proportion of Business
Aggregate all reports/issues over a specific time
Quality reports? Some clients have launched specific
period and assign consistent primary and secondary
campaigns around improvement, ideation, or gratitude to
categories to each issue. Your case management
drive higher employee engagement. Getting people to Speak
system or data warehouse should (hopefully) contain
Up about areas for improvement or areas of gratitude helps
this information. Once categories are assigned to each
to reinforce the organization’s desire for people to speak up in
case, determine the number of instances in each
general, and tends to drive more ethics reports overtime.

category and divide by the total number of cases


in the measurement period. This will give you your

Low employee engagement is a dynamic organizations have
proportion of cases by category. Repeat for other
become numb to, costing US companies approximately $0.5
equal measurement periods to compare trends

trillion per year.6 Not only do engagement campaigns show
over time.

employees that their voice matters, catalyzing the Speak Up

culture we are after, it also allows them to engage in the

Issue Category
reporting process in a positive way, making it easier to report Issue Intake

=
negative occurrences later when they see something.
Total Cases
by Category

6Ayu, Ariana. “The Enormous Cost of Unhappy Employees.” Inc.com, Inc., 27 Aug. 2014

Expanding Your Reach

Training efforts are a critical element in your overall compliance effectiveness. Countless scientific studies show the

comparative effectiveness of interactive, engaging, relevant adult-learner focused training. E-learning courses, often

incorporate short, topical reminder videos throughout the year that reinforce principles and battle the “Forgetting

Curve” that plagues us all. These can be effective to convey both important tenets of your ethics and compliance

program, and your organization’s commitment to providing the workforce with the information they need to behave

within the value set surrounding your mission.

As you try to do more yourself, it is often more difficult than expected: clunky content request, never-ending content

update schedules, cumbersome administration, or tracking completion across platforms. Choosing a training and

communication solution for your Code of Conduct or general E&C training can add a point of leverage operationally,

increasing your employee engagement and overall program effectiveness.

M a k i n g t h e w o r l d a b e t t e r w o r k p l ac e 17
Abandonment Rate: The Silent Killer

With almost 50% of employees witnessing

“reportable” misconduct each year (ECI)3 and less
than half them even attempting to report it
(Gartner),2 the Industry Standard of a mere <1.4 Industry Standard8 - High 19%
reports per 100 employees means there are many
more reports to get from our workforce.

Industry Standard8 - Low 15%

According to Harris Interactive, 75% of callers say it
takes too long to reach a live agent.7 A view of
scarcity with respect to reporting means we have to Average Inbound - High 16%
get every report we can.

That is to say, when someone goes through the Average Abondonment Rate 12%
trouble to pick up the phone, the last thing we can
afford to do is lose that report before it happens.

Average Inbound- Low 10%

Factors like call-queues, call trees, and long
wait-times before speaking to a human all
confoundingly add risk to your risk management World Class - High 8%
system by contributing to high abandonment rate (a
metric few like to discuss).

World Class - Low 5%

It is critical that each issue an employee attempts to
report actually turns into a report.

ComplianceLine9- High .83%

If your intake is subject to 15- 20% abandonment
rate, your reporting rate could be upwards of 25%
higher than you currently acheirve with your ComplianceLine9- Low
setup/vendor. .49%
7Harris Interactive Talk Desk Call Center Benchmark Report

8Reports from multiple new clients over last 12 months

9ComplianceLine Internal average gross abandonment rate,

Making the world a better workplace 18

4. Issue Days Open
2020

0-30 Days 79.21%

31-60 Days 10.17%

61-90 Days 3.94%

90+ Days 6.68%

Case closure rate is a key performance indicator for all E&C In 2020, E&C teams in our system rolled up their sleeves and
reporting programs. Reporters want to know that their issues worked tirelessly behind the scenes to keep people informed
are being taken care of in a timely manner, and E&C and working safely. ComplianceLine clients acheived almost
professionals need to know that risks are being identified and 80% of all cases closed within the first 30 days, with an
dealt with appropriately.

average case closure time of 25 days.

If too much time passes between report and resolution, This is almost a 5% improvement over 2019 (75%), which had
reporters often feel that they are not being taken seriously been relatively stable over the prior few years. This case
and may lose trust in the organization or the reporting closure rate is approximately 40% faster than the median
process. Equally important, organizations can open performance in the Traditional Comparison of 39 days.

themselves up to avoidable regulatory and legal risk when

cases are allowed to age too long.

Making the world a better workplace 19

 CL

2018 2019 Traditional Comparison

0-30 20% 75.32% 75.47% 0-30

Days
23% Days

31-60 14% 9.09% 14% 9.94% 31-60

Days Days

61-90 29% 4.22% 31% 4.56% 61-90

Days Days

37% 11.37% 32% 10.03%

90+ 90+
Days Days

Over this same period, aged reports in the ComplianceLine Because issues don’t stop occurring, it is important that all
dataset (reports over 90 days) fell from 11% in 2018 to 7% in intake channels remain open at all times, even in the midst of
2020, compared to 32% in the Traditional Comparison. This a pandemic or periods of social unrest. Continuing to apply
significant drop, which is particularly impressive given the operational excellence and adhering to your process is the
environment last year, indicates a general decline in days to best way to ensure you don’t get behind. This disciplined
process as a whole, which can mean overall less approach, coupled with the realization that “our value is not in
administrative work and higher ROI on compliance spend. our plan, but in our ability to plan,” frees us up to take an
agile, risk-based approach to everything, including our
The two biggest opportunities to reduce case investigations.
closure times are operations and intake.

Making the world a better workplace 20

Think About

What can you do to minimize the time to close your

How to Calculate

organization’s cases? Not only is it a best practice for general

Determine the number of days each issue is open

risk mitigation, reducing time to close also has follow on
and sum all the days. Divide the total sum of all Days
benefits to culture. When employees see that their cases are
Open by the total number of cases closed.
being closed quickly, and when the results of those cases are

communicated back if possible (either through policy

changes, education, or even anecdotal stories in

company-wide newsletters or leadership presentations), your

people see that their voice matters and something is being Total Days Open
Issue Days
done about their concerns.

=
Open Rate Total Case Closed

This can also be improved by making sure your intake is high

quality (make test calls to your own line to assess). This

means ensuring that empathetic elicitation is in place and

that interviewers are both risk-trained and able to apply a

flexible approach to gathering information. Also take a look at

your directives, and review all open cases as a team weekly,

or even daily, to optimize your process. These two areas --

operations and intake -- present the biggest opportunities to

reduce case closure times.

M a k i n g t h e w o r l d a b e t t e r w o r k p l ac e 21
 5. Issue Anonymity
100%
60.53% 64.37% 67.97%

80%
% Identified

60% % Anonymous
57% 59% 58%
Traditional
40% Comparison
39.47%
35.63%
32.03%
20%

0 2018 2019 2020

Issue Anonymity is a critical datapoint to evaluate, as it can prefer an anonymous option. That is to say, none of our
demonstrate aggregate workforce trust in both the clients in the sample (who offer anonymity as a reporting
organization and the reporting process. Higher anonymous option) with more than 100 reports had zero anonymous
rates indicate lower trust, while lower rates indicate a lower calls.

fear of retaliation and a higher level of employee ownership.

While we have seen identified reporter percentage change An anonymous rate significantly higher than 60% could
almost 8% over the measurement period, the overall mix has indicate some trust issues with the organization in general, or
remained relatively stable at 65%/35%, identified to with respect to the reporting process in particular. This may
anonymous. However, in general, fear of retaliation is on the be due to several factors previously mentioned, but is usually
rise across the world. (see Special Report: Troubling driven by a general fear of retaliation and/or a poor reporting
Retaliation Trends, page 25 for more details).

 process (e.g., painful, long wait times, lacks empathy).

Traditionally, the lower the anonymity rate, the more trust Organizations showing high Anonymous Rates usually see
reporters have in the organization. However, absent an symptoms of cultural short-falls in other areas of the
impenetrable culture of trust, some issues will only be operation, such as lower employee engagement, relatively
reported under the cover of anonymity. Even in the healthiest higher turnover rates, and often higher material lawsuit rates.

organizational cultures, some personalities or issues willl

Making the world a better workplace 22

 2020 Issue Anonymity by Sector

100%

69.32% 60.00% 49.87% 66.85% 62.17% 63.46% 32.46% % Identified

80% 83.82%
% Anonymous

67.54%
60%

50.13%
40%
40.00%
37.83% 36.54%
30.68% 33.15%

20%

0 Health Care Industrial/ Energy Financials Tech Utilities/
 Other

Materials Telecom

Anonymous reporting is a pillar of the issue intake process. Rate in isolation. It should always be considered in the
Offering and gaining employee trust to speak up and submit context of other factors. A high rate of anonymous reporting
a report while keeping their identity confidential is beyond a may indicate that employees withhold their identity out of
best practice -- it’s critical to protect your employees and fear of retaliation for even relatively innocuous issues, which
empower the E&C team with essential, sensitive information.

is a potentially dangerous place to be. In this case,

employees are not comfortable entrusting their name or
The chart above presents Anonymity Rate by sector. Health other identifying information to Management.

Care, among the hardest hit last year, had the lowest
Anonymity Rate at 31%, but was inline with our overall On the other hand, a low Anonymity Rate may indicate that
average of 32% in the sample. Energy sector had one of the employees have an especially high trust in the process and
highest Anonymity Rates once again, this year settling in at team. In this case, your employees are comfortable reporting
over 50% of reports (62% last year). All sectors showed the especially sensitive issues due to their ability to stay safe in
general decline in Anonymity Rate seen in the overall reporting. Here, you receive more sensitive issues earlier and
benchmark.

with more frequency than your peers, who may operate in a

lower trust environment.
However, it is difficult to read too much into your Anonymity

Making the world a better workplace 23

Think About Sensitive Issues (severity or category)
What is your Anonymity Rate? If it is significantly higher (10%+) A high relative incidence of sensitive/severe issues and high
than the 30-35% stable trend we see in our data, examine Anonymity Rate may mean you’ve built a strong culture and
whether a lack of trust is an issue in your organization. Gain the ability to remain anonymous is enabling earlier visibility

insights from employees through roundtable discussions, into thorny issues, especially if the per capita reporting rate is
anonymous surveys, or through cultural consulting relatively high.
engagements. Even a simple datapoint from a Google Forms
(or other free survey) can provide a baseline you can work to Anecdotal Cultural Indicators (cooperation with and trust in
improve upon. Further, examine the reporting process, issue the E&C team)
intake and case management processes, and the resulting Compare metrics to your sense (or a rough sampling of
outcomes with an unbiased eye.

employee sentiment) of the trust in your process. While less

objective, this can help you form some assumptions to
Factors such as lack of empathy on intake (where speed and monitor and measure against.
efficiency are often more important to profit-centric vendors
than treating people like people), lack of follow-through,
extended periods of unresolved cases, and lack of
communication back to reporters all contribute to lack of How to Calculate

trust. Remember, people don’t report for two major reasons:

fear of retaliation and/or they don’t think Management cares Divide your number of anonymous issues

(or won’t do anything about it). As E&C professionals driving a by total issues to get your anonymous reporting rate.

Speak Up culture, this is our responsibility -- and luckily, it is Subtract the anonymous reporting rate from 1 to get
possible to improve in virtually all cases.

your identified rate.

Consider triangulating your Anonymity Rate with other

indicators in your reporting system, like reporting rate, Anonymous Issues
substantiation rate, and case closure times to get a better Anonymous Rate =
understanding of the nature of your Anonymity Rate and Total Issues
clues to improve it.

Total Issues
Low incidence of overall issues and high Anonymity Rate may
indicate a reticence to engage and a preference to remain
Identified Rate = 1 - Anonymous Rate %
anonymous, even when less necessary due to low trust.

Making the world a better workplace 24

Troubling Retaliation Trends
Several interesting data points have recently emerged that create tremendous cause for concern. Here we present some of
these data and discuss possible root causes and correlations, along with implications and opportunities.

Only 1 in 5 people are “experiencing strong ethical cultures” Of course correlation doesn't equal causation, but it is
per ECI’s 2021 State of Ethics & Compliance In the Workplace interesting considering these data points together: SEC
report.3 We also know that a ton of stuff doesn’t even get Whistleblower reports, % of Employees Experiencing
reported -- almost 60% according to Gartner.2 So why don’t Retaliation, and Proportion of Millennials/GenZers in the
people speak up?
workforce from 2012 to 2020.

The main reasons people don’t speak up include their belief Millennial/GenZ % 
 SEC Whistle- Employees Experiencing
that no one cares (25%), not sure if issue is big enough to of workforce blowing Tips Retaliation
6,911
79% 80%
report (26%), and not sure if it’s their place to report (24%). But 8,000
the largest factor by far is fear of retaliation (43%).4 This fear is
on the rise, and apparently with good reason.

75% 60%
5,282
6,000
58%
ECI’s report also shows 79% of employees who spoke up 3,923
44% 40%
experienced actual retaliation, up almost 2x from 2017 (44%) 4,000
3,001
48%
and 3x from 2014 (22%).3 This is staggering.

40%
22% 35%
31% 20%
24% 27%
2,000 22%
This trend seems to coincide with a significant increase in 20%
SEC annual whistleblower tips, which has almost doubled
from 2014 (3,620 tips) to 2020 (6,911 tips). 10

0
2012 2013 2014 2015 2016 2017 2018 2019 2020 2020-2030

So what’s causing these jumps? Well, 2020 was a weird year, We are in the midst of the biggest workforce generation
so it’s unclear the extent to which these levels will “revert” in transition in almost a century. Millennials and GenZers, who
“normal” years. For example, this past year over 44% of accounted for less than 50% of the workforce in 2019, are
employees experienced increased work-related pressures to projected to account for 75% in the next five to 10 years.

meet performance goals, to always be available, and to show

value in the midst of a pandemic.1 These types of conditions This large group is inheriting workspaces designed by and for
often create pockets of moral hazard, breeding all kinds of Baby Boomers. However, these groups can be extremely
misconduct. different in their expectations for work, lines of hierarchy, need
for organizational impact, desire for missions that resonate
10.U.S. Securities and Exchange Commission, 2020. Whistleblower Program. Annual Report to Congress.
with personal purpose, and a myriad of other factors.

Making the world a better workplace 25

COVID-19 notwithstanding, this generational shift may prove The opportunity lies in attacking these issues directly on both
to be the driver at the root of these surprising trends. The fronts. Root out retaliation with a campaign where you talk
workers taking up leadership in our workplaces are a about ways everyone can identify and prevent it. Get
relatively more vocal. ECI shows 86% of 2020 respondents managers to push the anti-retaliation message internally;
claimed to report some or all observed wrongdoing, up over bonus points if you can build it into performance reviews.
25% in the last 10 years.3 Our next generation of employees Provide incentives for people to report retaliation, and raise
are willing to Speak Up, more so than previous generations.

the alarm to other leaders and culture champions that the

fear of retaliation might be an unexpected issue and potential
However, new generations are also attuned to inauthenticity, cultural risk.

greenwashing, and other altruism scams -- which all extends

to their work environment: 70% of respondents said they Educate your workforce on the availability of your hotlines
would be more likely to report if they believed there was a and webforms, and make the minor investment to meet them
truly anonymous option, with only 56% clear on what where they are at with the right tools -- smart technology and
reporting options were available to them.4

humanized intake. Remember that many don’t believe the

anonymity is real, so educate them on the process and the
So what are we supposed to do? Well, let’s break it down:
controls in place. Provide blinded stories about investigations
New generations are more vocal and a big shift is coming and outcomes, and celeberate the Speak Up heroes who
very quickly. There are untold numbers of unreported issues. have shown courgae in your organization.

People don’t report because they are scared of retaliation,

and 4 out of 5 who do report internally are feeling retaliation Assume this problem is going on in your organization. Even if
of some kind. And only 1 in 5 believe they are in an ethical your situation is half as bad, that’s 40% of people speaking up
culture, while less than half belive in the process or know that are experiencing retaliation -- and that is too high.

their options.

The organizations that recognize the opportunity this

This seems dire. But most of the time a troubling trend can generational shift presents and repositions themselves in
be flipped into an opportunity if acted upon quickly enough.

minor ways will generate authentic top performance that

can’t be replicated easily.

The reasons people don’t speak up fall into two categories.

Education accounts for approximately 50%, and includes But doing so means taking advantage of the generational
reasons such as not being sure if the issue was big enough shift -- tapping into the hearts of your employees by giving
(26%), or not their place to report it (24%).

them a voice and valuing that voice. Human beings are better
risk managers than sensors, but only if they are informed and
Retaliation accounts for Approximately 43% and includes empowered.
factors such as fear of demotion, job loss, shaming (28%), and

seeing the negative way other reporters are treated (15%).4

Making the world a better workplace 26

 6. Issue Severity Level

100%
8.25% 8.65% 9.86% Severe/Urgent
8.47% 7.75% 7.50%
80%
83.28% 83.60% 82.54% Severe/ Non-urgent

60% Regular

40%

20%

0 2018 2019 2020

Severity Level I (Severe and Urgent)


This is the highest priority of a reported issue, as it is both a serious and imminent threat to a person, property, or environment,

or one that just occurred. Best practice is to make immediate, direct notification to coordinators upon termination of the call.



Severity Level II (Severe, but not Urgent)


The second-highest priority of a reported issue, defined as a serious situation that requires prompt attention, but does not
require immediate action. These calls are typically ongoing situations like drug and alcohol use, workplace violence, or patient
care issues that are not occurring at the time of the call. Notification to the client coordinator(s) upon termination of the call is
made.

Severity Level III (everything else)


Calls that do not require immediate action. These follow the standard digital (e.g., email or case management system) notification
procedures.

Making the world a better workplace 27

Over 2018, 2019, and 2020, there was no significant change in Deeper operational problems

the proportion of “Regular” calls across the sample. However, 3 If your reporting rate is normal and your categories are
last year showed an increase in “Severe/Urgent'' calls to
clear (i.e., you are satisfied that severity designations are
almost 10%, largely due to Covid-19 concerns, and we saw
legitimate), then a high severity rate is typically rooted in
the greatest jump coinciding with the height of the pandemic.
some kind of systemic, real problem within operations.
Generally, this metric has tended to exhibit statistical stability
These situations should be handled on a case-by-case
around midyear over the periods presented, increasing the
basis, usually by teams specialized for the respective
confidence interval of comparability between periods.

problem areas. E&C can support the eventual solution

and outcome with an appropriate response, relevant

In 2020, we saw approximately 83% of calls falling into
training, and adequate process and policy changes.

Severity III (Regular) with the remaining 17% split between

Urgent (9.9%) and Non-Urgent (7.5%).



If your organization’s aggregate severity rate is higher than

15-20%, the reasons are typically due to:

How your hotline is used

1 What is the nature of your line? If it is only used to report

severe things then your severity rate will of course be

relatively higher, but this will also (hopefully) coincide with a

low reporting rate. Consider whether severity rate is different

across reporting channels (e.g., more mundane issues

reported Online).

How you categorize severities


2 When was the last time you reviewed how your severe

reports are determined and handled/routed? How

cooperative is your vendor in making those changes? In some

cases, high severity levels were due to issues being

incorrectly categorized as “severe.” Analyze your severity

categories and sample a handful of recent severe reports and

to confirm whether they were properly categorized.

M a k i n g t h e wo r l d a b e t t e r wo r k p l ac e 28
2020 Issue Severity by Sector
Non-Urgent
7.23% 7.23%
10.19%

20% Urgent
7.23%

7.55%

6.48%

6.71%

8.45%

0.78%

10.93
10.95%
10% 10.95%
%

9.23% 9.86% 9.78%

8.33%

1.86%
4.39%
0.48%
5.28%
3.37%
3.17%
1.25%
0.43% 1.15%
0.64% 0.93% 1.93%
1.56% 0.95%
1.28% 1.07% 1.13%
0.36%

2019 2020 2019 2020 2019 2020 2019 2020 2019 2020 2019 2020 2019 2020 2019 2020
0
Health Care Industrial/
Energy Financials Tech Utilities/
 Other
Overall
Materials Telecom

Issue Severity by sector tells an interesting story in 2020, increases were seen in industries like Health Care, Industrials,
where the far-reaching impact of Covid-19 on severity Energy, and Financials. Severe issues ranged from PPE
increases corresponded almost directly to whether or not the deficiency calls from health care workers facing life
sector was predominantly staffed by of “Essential Front-line threatening risks, to the large uptick in Financials with calls
Workers.” Predictably, Tech and Other showed declines in about relief funds that were requested inappropriately or
both Severity categories, while significant misused once disbursed.

M a ki ng th e wor ld a b etter work pl ac e 29

Think About

All else equal, how can you decrease the incidence of severe How to Calculate

cases? In most cases, it is possible to reduce the proportion Aggregate all your reports over the time period to be

of severe cases through operational quality improvements. If analyzed and apply a severity level to each. Sum each

the solution will be outside of your control, you can help drive severity level type and divide each total by total

these operational improvement efforts by making sure issues to get your percentages.

someone knows about what you’re seeing, and support with

appropriate training, policy changes, etc.

Total Severity Level Type

Crowdsourcing potential solutions from your broader team is Issue Severity
=
helpful in addressing an issue like this, especially from those
Level Rate Total Issues
on the front-lines. Many of these folks have amazing insights

and ideas that are often underutilized. Furthermore, front-line

participation in problem solving greatly increases the

likelihood of buy-in to the ultimate solution initiatives.

Showing authenticity coupled with employing a “Fair Process”

to drive lasting change management can be helpful.

The far-reaching impact of Covid-19 on severity

increases corresponded almost directly to

whether or not the sector was predominantly

staffed by “Essential Front-line Workers.”

M a k i n g t h e w o r l d a b e t t e r w o r k p l ac e 30
 7. Issue Validity Substantiated / Unsubstantiated

100%

63.22% 44% 64.65% 42% 57.15% 41%

80%
Substantiated

60% Unsubstantiated
58% 59%
56%
Traditional Comparison
40%
42.49%
36.78% 35.35%

20%

0 2018 2019 2020

Issue Validity refers to Substantiated vs. Unsubstantiated Despite this decline, our clients’ substantiation rate remains
reports. It is important to monitor Issue Validity, as it is an almost 1.4 times higher than the Traditional Comparison
indicator of overall report quality made by reporters, and the benchmark of 41% indicating stronger cultures, better intake,
quality level of your investigation operations. Analyzing this and better software and processes.

metric also helps ensure that reports are being properly

investigated and resolved and the workforce has appropriate Time will tell whether the 2020 decrease in substantiation is a
training on what is worth reporting.

“New Normal'' or an anomaly that will revert toward the

longer term average over time. Continuing to focus on
This metric saw a significant decrease from 65% building trust in both the reporting process and the
substantiated in 2019 to 57% in 2020. The WFH environment organization’s genuine desire for folks to Speak Up, as well as
caused a decline in in-office/in-person reporting, which on educating people about the types of things to report and
exhibits a naturally higher substantiation rate over time, and how/where to report are best practices to systematically
that shows up in the declining substantiation rate last year. improve your substantiation rate.

Making the world a better workplace 31

 2020 Issue Validity by Company Size
100%

51.33% 53.08% 43.38% 37.36% 74.49%

80%
83.82%

60% Substantiated
62.64%
56.62%
48.67% 46.92% Unsubstantiated
40%

25.51%
20%

0 < 1,000 1,001-5,000 5,001-10,000 10,001-50,000 50,001+

To achieve a high rate of substantiation, you need both a at scale tends to be more difficult (in addition to having more
healthy starting point (meaningful/verifiable issues are issues reported with minimal information). Interestingly, the
reported with sufficient information gathered at issue largest companies in our sample have achieved a scale
creation) and a robust investigation and follow-up process. (operations, headcount, budget, process, etc.)that enables a
Either of these may explain the disparity across company 2020 substantiation rate of 74% across thousands of issues
size.

each year. Noteably these large organziations present a

below average (but still commendable) reporting rate of 2.4%.
While E&C teams adjusting to WFH this year drove down As with all these statistics, context improves the story.

average report days open to 26 days (See 4. Issue Days Open

for more information), substantiation rates suffered due in
part to a significant number of employees not being onsite. Substantiation Rates suffered due in part
Virtually all company sizes saw declines in Substantiation from not being onsite. Virtually all company
Rate over previous years.

sizes saw declines in Substantiation Rate

Substantiation rate declines by company size until an over previous years.
inflection point among extra large organizations. As
companies grow, ensuring thorough information upon intake

Making the world a better workplace 32

Think About

How does your substantiation rate compare to this How to Calculate

benchmark? How does it compare to your own substantiation
Divide your number of substantiated cases by the total
rate from prior years? If there is a deviation, why did that
number of closed cases. Exclude open cases to
happen? If your rates have declined or if they are
eliminate noise from your results. Repeat the process
substantially lower than 50-60%, try to figure out where the
for the previous period (e.g., quarter, year) to analyze
problem lies. Is it on the investigation side, the intake side, or
internal trends and areas to improve.
the employee education side?

If your investigations are attentive and quick, and cases are

being closed in a timely period (<30 days 8/10 times), the

Total closed Unsubstantiated 

-
unsubstantiated issue problem is like on the reporting side --
Substantiated cases Cases
which means on either the employee education side or the =
Rate
Total Closed Cases
issue intake process side. Here, develop awareness

campaigns to educate employees throughout the year about

the purpose of the hotline and the process; share anecdotes

in company newsletters of blinded stories about things

reported, investigated, and how they were handled; and get

Unsubstantiated
other leaders and culture champions to mention Speaking
Case Rate
=
1 - Substantiated Rate %

Up, using the helpline, etc. in correspondence and company

meetings.

If cases are taking longer than 30 days to close most of the

time, focus on the investigation process. Provide increased

oversight of the process (distributed vs. centralized) and

consider additional training for investigators. Set S.M.A.R.T.

goals for case closures and work with your team to achieve

them over the coming quarter to drive improvement.

Ultimately, you may want to consider outsourcing some or all

investigative work to increase capacity.

M a k i n g t h e w o r l d a b e t t e r w o r k p l ac e 33
Expanding Your Reach

While an ethics and compliance hotline can help to find out Disclosure Forms
about more unknown risks within your organization, there are
a myriad of complementary tools to leverage your impact Managing disclosure across the organization can be confusing and
cumbersome, while often leaving you feeling like “you don’t know what
while getting your workforce to Speak Up. These tools can
you don’t know.” Look for technology-based solutions that can
automate, organize, simplify, and augment your traditional automate this process, target the appropriate employee groups, are
intake channels to better meet your organizational risk needs simple enough so people actually use them, and aggregate all your
while meeting your people where they are at. disclosures in one place. This reduces both cost/time and risk --
allowing your team to focus on what they do best -- managing the actual
Mobile Applications risks of the organization.

As the workforce becomes more digitally fluent and reliant, it is smart to Conflict Of Interest
meet folks where they are at with intake tools that are flexible and gather
the right information. While most mature programs have web reporting Like disclosure forms, managing conflicts of interest (C I) can be
O

available, some are not optimized for mobile devices. Many programs daunting. Again, technology should be leveraged here to ease the burden
have found it difficult to gain meaningful traction with actual apps that and get the risks wrangled, and we don’t mean email and spreadsheets.
need to be downloaded so more are moving toward more success with H aving C I forms that are easy to distribute, and keeping those results
O

“web apps.”

in one searchable database helps immensely to transform the

reporting/approval processes for both HR and Compliance Teams. This
These are websites that provide a full app experience without the need to also provides a means to capture insights into potential risks more readily.
download the app. Layering in Artificial Intelligence (AI) into these intake
forms to ask better questions (yes, AI for E&C exists finally!) can help get Ex it Interviews
the best of both worlds: app experience that folks are used to, and will
Exit Interviews are a powerful tool to uncover unknown risks. The number
actually use, while getting better information than static forms.
one reason people don’t report wrongdoing is fear of retaliation. This is
something that is e ectively eliminated when someone is leaving your
Training and ducation
E
ff

organization, especially when leaving voluntarily.

Your training e orts are a critical element for your overall compliance
ff
The level of candor and transparency departing teammates o er is
e ectiveness as it sets the foundations of a credible culture of integrity.
ff
ff
typically invaluable. Standing this process up if it doesn’t exist, or taking it
Educating your workforce with learning that they actually take
over from and incorporating the results into the case management
provides a model of the right behaviors you want your team to e hibit.

HR
x
system that already holds all your other realtime ethics reports, allows
for a data analysis enhancement that helps to better identify
Augmenting training plans to have brief follow up reinforcement
potentially systemic risks.

throughout the year to complement annual, pillar training, with

behavioral-science based reminders and awareness materials/posts can
Exit Interviews best practices are that E&C controls the process, to
do much to actualize compliant habits across your culture .

provide di erent options for folks to report (web, phone, etc.), use
ff

third-party to o er anonymous options and reduce scheduling friction,

ff

make them compulsory (add to your Code or o -boarding processes),

ff

strategize in-bound vs. out-bound strategy, consider providing incentives,

and share results with .
HR

 8. Issue Sequence (Original Calls / Follow-up Calls)

Issue Sequence
100%
17.30% 16.90% 16.00% % of Follow-Up Call

80% 82.70% 80% % of Initial Call

83.10% 84.00%
Traditional Comparison
60% 64% 67%

40%

20%

0 2018 2019 2020

Follow-up calls are crucial for case managers to initial report, or a lack of trust in the reporting process
communicate back to the caller, recieve reports about repeat (especially in cases where the caller remains anonymous).
issues, and gather additional report information to resolve the Having a smart intake method that is able to adapt in order to
caller's concern, question, or request. We identified the get the right info is the easiest way to fight that. By gathering
number of follow-up calls required to clarify or update sufficient information on the first call, you can drive down the
information from 2018 to 2020. Follow-up calls make up need for follow-ups.

about 16% of the call volume, decreasing from approximately

17% in 2019.

However, we do not find a statistically significant difference

when considering anonymous versus identified callers for
Typically, the more follow-up calls submitted on a specific this metric and, therefore, don’t break these out separately.
concern, the more complex the case (or the more distraught Follow-up rates tend to move inversely with case closure
the reporter). Complex cases tend to stay unresolved longer. duration. Generally, a lower follow-up rate indicates that
In some situations, however, follow-up calls may be a result cases are being closed quickly and that ample initial
of insufficient information gathered from the caller during the information is gathered during the initial intake call.

Making the world a better workplace 35

 2020 Issue Sequence by Sector
% of Follow-Up Call % of Initial Call

100%

23.90% 19.70% 15.50% 27.30% 19.30% 19.77% 11.10% 20.00% 17.00% 18.80%

80% 88.90%
83.82% 84.50% 83.82%

80.30% 80.70% 80.23% 83.00%

80.00% 81.20%
76.10%
72.70%

60%

40%

20%

0 Energy Financials Health Care Industrials Materials Other Real Estate Tech Telecom Utilities

This graph demonstrates follow-up call to initial call volume of the pandemic in 2020. Because we were in uncharted

by sector. The average follow-up call volume across all territory, coupled with many within the Industrial sector being

sectors for 2020 is approximately 16%, which is on trend with deemed essential workers, there was a dearth of clear

2019’s findings. The Industrials sector had the highest policies on pandemic protocol. Here, both parties (reporter

follow-up call volume (27%) and the real estate sector had the and investigator) were unsure what the solution/action would

lowest (11%) last year.

be, leading to increased follow-up activity. Real Estate, on the

other hand, was among the sectors hardest hit by the

The shift in the industrial sector was seen highest at the start Covid-19 shutdown, and saw their follow-up rate fall to 11%.

Making the world a b e t t e r w o r k p l ac e 36

Think About

What is your ratio for issues that require followup to their How to Calculate

original report? How has it moved relative to last year? If your

Find the number of cases where a caller returned

follow-up rate is significantly higher than 20-25%, you may
to the system to follow-up on a report. Divide this
have a problem either in taking too long to close cases, or an
number by your total cases to find the follow-up rate.

opportunity to improve communication back to the reporters
Subtract your follow-ups from total cases and divide

and the workforce as a whole.

by total cases to get your original issue rate.

Separately, if callers repeatedly follow-up with additional

details, you need to further diagnose to determine whether

the repeated follow-ups are due to a trust issue (e.g., callers

are testing the process before divulging everything) or an Total Calls - Follow-up Calls
Original

initial intake issue (where perhaps an adaptive interview is not =

being employed). The latter can be caused by an

Issue Rate Total Calls

over-emphasis on speed and efficiency (cost minimization)

over empathy and effectiveness (information maximization).

Follow-Up Calls
Follow-Up

=
Rate Total Calls

M a k i n g t h e w o r l d a b e t t e r w o r k p l ac e 37
 9. Reporter Awareness
Reporter Awareness
100%
10.60% 28.89% 36.80% Internet
21.37%
80%
Poster/Flyer/Brochure
18.22%
14.85%
60% 15.04% Company Communication

9.62% 13.13%
11.07% Employee/Colleague
8.31%
40% 9.30% 9.38%
35.25% 7.13% Intranet
6.28%
23.33% 21.44%
20%
All Other Communication Tools

0 2018 2019 2020

Reporter Awareness is critical to track as it demonstrates The graph above shows how reporters were made aware of
which awareness efforts are driving engagement from your compliance resources. These data points show a clear trend
employees. Evaluating your awareness sources and types toward the effectiveness of digital awareness channels, with
against the benchmark identifies successful engagement the Internet increasing 8% to 37% in 2020.

paths as well as media you might be under-leveraging (and

thereby missing opportunities for information and employee The rise in the Internet as an effective awareness channel
collaboration).

over the past 2 years has come at the expense of almost all
other awareness types, including referrals and
Track and compare Reporter Awareness to ensure your word-of-mouth. Interestingly, even captive company
employees are informed about the reporting resources Intranets (HR portals, et. al.) have declined in favor of
available to them. employees searching company sites or other web postings
for compliance reporting options.

Making the world a better workplace 38

Think About

What awareness methods are you trending behind on? How How to Calculate

have yours changed overtime? Do these differences indicate

Identify all issues reported by channel and sum

a difference in culture (such as a more digital-dependent
the total reports per channel. Divide the channel

employee population) or an opportunity to engage a
total by total cases.
previously left behind portion of your employee base? A high

level of employee/colleague word-of-mouth awareness can

indicate a more pervasive and open culture of trust.

Also consider a web-based Ethics Portal that is readily

Channel
Reporter
available and easily accessible to all employees (i.e., the top
=
Awareness Rate
Total Cases
of the Google results page). This can quickly provide

employees with all the information they need in one place.

Share access to this portal everywhere -- on social, in email

signatures, and in company-wide correspondence.

Finally, consider refreshing your awareness materials and

overall strategy. How are you adjusting your focus to drive Reporter awareness data points show
reporting in a remote work environment? If your company is
a clear trend toward the effectiveness
coming back in-office or staying remote, it is important to
of digital awareness channels.
adapt to continue to drive reporting rates higher. Awareness

should always incorporate the best practices from cognitive

psychology to help change behavior and drive action (e.g.,

Second-hand reporting: “Speak Up. Because she won’t.”).

M a k i n g t h e w o r l d a b e t t e r w o r k p l ac e 39
 10. Reporter Type
Reporter Type
100%
63.83% 63.33% 56.45%
Employee/Former Employee

80% Customer/Patient

Family Member
60%
Not Selected / Anonymous

40% 12.57% Other

10.79% 11.37%
19.79%
16.23% 15.61%
20%
3.67% 4.14% 5.90%
5.48% 5.55% 5.29%

0 2018 2019 2020

Reporter Type indicates the relationship of the reporter to the The proportions depicted in your hotline reporter types

organization. Calls from employees and former employees will be a function of how your hotline is used, and how it is
represent the highest identified issue volume. 

advertised internally or externally. However, examining mix
trends over several comparable periods will provide insights
There was a jump from 2019 to 2020 in Family Member into how you can improve your issue intake operation.

Category. This was a direct result of the Covid-19 Crisis,

especially in the healthcare sector.

Making the world a better workplace 40

Think About

How to Calculate
How do you use your hotline, and where do reports that
Categorize issues by reporter type. Sum each
signal risk originate? If you’re trying to build customer or
category and divide by total reports.
community relations, look for trends in those reporter types,

and drive awareness there.




Low metrics against our benchmarks indicate opportunity to

build external awareness. Likewise, if employees are your Sum of Reporter Type
Reporter

source for reports that flag internal risk, low metrics indicate a =
Type Rate
need for more employee education, awareness, and training. Total Reports

The proportions depicted in your

hotline reporter types will be a function

of how your hotline is used, and how it


is advertised internally or externally.

M a k i n g t h e w o r l d a b e t t e r w o r k p l ac e 41
 What About Hotline 3.0?
A Compliance 3.0 program is one that strategically uses tools in place in the right ways to drive the right behavior in their
organizations sustainably. Below we outline several aspects of an E&C hotline and how you can optimize strategically as part of a
Compliance 3.0 schema.

Analytics Metadata Quality Categories Intake

No longer drowning in lakes Your case management Your categories are as simple Your calls are answered
of data, you now sit casually system is full of metadata, or as possible, but no simpler. quickly, and people calling in
and sip ice cold glasses of data that provides The structure is logical and are treated right. The
information. You focus on the information about other data. stable over time. It is tied to experience your employees
big picture and only a handful You use data feeds of your Code and your E&C have is inline with your
of key analyses, with an eye locations, etc. from other training to help identify culture and employer brand.
for large year-over-year systems to keep your case remediation for problem You test your line and
fluctuations. You know “the management system info areas within the organization periodically review your
why behind the what” for the fresh. And because your more quickly. You review your intake, which is not annoying
metrics that matter and information is clean and up to cases and work with Intake to or cumbersome but allows
attack root causes with a date, comparisons over time fix miscategorizations to for natural flow while getting
Pareto approach.
are easy and clear. maintain data consistency. the right information.

Specialty Ideation Gratitude Exit Interviews

You strategically use your You are a student of You add a “Gratitude” You have successfully
intake in creative ways. behavioral science and category and increase lobbied for compulsory exit
During the pandemic, you understand Replacement reporting rates by getting interviews on all voluntary
worked with Intake to update Theory in driving human people in the habit of separations, and integrated
and enhance your directives behavior. You work with speaking up about things this intake into your existing
with Covid-19 information. As Leadership on a program to they are thankful for. This case management system.
part of your new DE&I get employees to Speak Up both reinforces the culture in You have uncovered several
initiative, you helped the with ideas for improvement in a positive way, while getting unreported systemic risks as
Chief Diversity Officer in their departments. You show people in the habit of a result, you are helping to
gathering stories of inclusion them their voice matters.
speaking up. improve employee turnover
within your company. in a meaningful way.

Making the world a better workplace 42

Conclusion Here are some actionable steps to focus on to drive a more
impactful program:

No matter what’s going on in the world, Ethics and

z
Recogni e that your hotline can be used strategically to

Compliance leaders work to make their workplaces better

Y
start conversations. ou can only crowdsource risk
management sustainably by making intake the start of a
every day. Last year showed the value E&C plays in keeping
conversation. Humanizing your intake process by treating
our organizations safe, informed, connected, and working.
employees who speak up with respect leads to more reports,
Now is the time to elevate E&C to become a true strategic
better information, and quicker investigations. Communicate
lever, and ascend out of the cost center pigeonhole many
outcomes back to the workforce to show that concerns are
find themselves in.

valued and acted upon to drive more Speak Up.

The 2021 Ethics and Compliance Hotline Benchmark Report

equips you with data points and ideas for greater strategic
z
Reali e that your hotline is a tool for your entire

contribution to the people and mission you serve.

z 3
organi ation. The Compliance .0 program is fully integrated
Y
with the organization. our hotline can help make E&C be
more collaborative by breaking down silo walls between
If you’re not measuring it, you’re not managing it, so it’s
important to keep an eye on your own trends, as changes are
ff P
departments. O ering tools in place to help roduction’s
safety push or HR’s D&I project helps forge strong, strategic
often early warning signs of deeper cultural issues or brewing
relationships.
risks. Many studies focus on average benchmarks. However,
in our ever-changing work environment, average is the new
Remember that your first clients of your hotline are your
bottom. We encourage you to set your sights higher.

employees. It's impossible to have an organization your

clients love if it’s not full of people who love it first. Driving a
Compare your results with the benchmarks, as well as your
Speak Up culture means encouraging employees to raise
own historical results. Aim for continuous, steady
their hand when they see something. This requires
improvement, and apply a risk-based approach to projects to
psychological safety -- because retaliation is real -- so make
make your workplace the best it can be.

sure your process is designed with the employee experience

in mind.
Over the next 10 years, ethics and compliance professionals
will show their impact by driving the right behaviors in their Rethink how your hotline can be used. Adding additional
people, by operationalizing DE&I and ESG to improve the capabilities to your hotline, such as Exit Interviews, ideation or
lives of all stakeholders, and by using their tools strategically gratitude lines, D&I lines, or stakeholder information
to influence the employee experience with an authentically resources, creates operational leverage for over-worked E&C
ethical culture.

teams, allowing them to find more of the risks that matter and
focus more strategically. Further, specialized lines as part of a
Let’s make the world a better workplace together.
Speak Up push can show your commitment to hearing your
employees input and your commitment to specific culturally
important issues.

Making the world a better workplace 43

About ComplianceLine
For more than 20 years, ComplianceLine has put our We have helped E&C leaders investigate nearly 10 million
customers and the quality of our work before profits to reports, offering employees the industry’s leading-edge tools
become the leading provider of ethics and compliance (E&C) to report unethical or illegal behavior free from retaliation.

solutions and second- largest player in the space. Our clients

trust us to listen to their employees and empower us to assist Our client companies include Fortune 500 companies, such
in the identification of unethical, illegal, and questionable as International Paper and AT&T, a higher concentration of
behavior.

risk-conscious industries, including 6 of top 7 US healthcare
systems, and brands of all sizes who value their people and
In building this trust, we have provided compliance solutions
 their impact, like Johns Hopkins University, Raytheon, Blue
in 50,000 locations to more than 6 million employees in 100+ Cross Blue Shield, and numerous county and city
countries through our highly-trained, caring, and compliance-
 governments.


minded professionals.

Our services:

Hotlines
 Compliance
 Compliance 


(Issue Intake) Awareness Programs Training

Case
 Credential
 Sanction


Management Monitoring Screening

Making the world a better workplace 44

 Making the world

a better workplace
COMPLIANCELINE.COM

800-859-8840