Issue Reporting: Take Action Now!

whistleLet’s face it; several companies could have avoided public scandals if they had functioning, efficient whistleblower functions in place to catch issues early. Not only is an effective whistleblower function a key element of corporate governance, but the Sarbanes-Oxley Act mandates that a company has a whistleblower function designed to protect the reporter.

We know that corporations have spent a lot of time and money in setting up these functions but unfortunately it seems that some companies still aren’t doing a good enough job at “policing” themselves.   In come the whistleblower bounty rules under the Dodd-Frank Act, allowing a whistleblower to earn as much as 30% of any settlement the SEC wins based on the information provided to the SEC by the whistleblower.

I’m sure this has plenty of compliance officers frustrated.  Not only do they need to convince people that reporting these issues early is the right thing to do, now they must find a way to compete against potential multi-million dollar payouts to get that information from whistleblowers!

So what can you do?  You can start by making sure that your internal channels of issue reporting are easily accessible and that your corporate culture encourages open and honest feedback.

Did you know that policyIQ has a whistleblower module?   I realize that all SOX compliant companies already have something in place, you might even be using the module in policyIQ already, but I wanted to share some benefits of this module with the rest of you who might be interested in a way to capture anonymous feedback or even those that may be looking for a different tool.

    1. WhistleBlower is not a separate system. Since WhistleBlower is in a system used frequently by employees, there is no risk that employees do not know where to go when they have an issue. Plus, it’s not going to cost you any extra money! Read Only Users (which are always free) can submit cases.
    2. Consider renaming the module and using it for other types of anonymous feedback. You could rename the module something like “Feedback”, “Suggestion Box” or “Issues” and provide a great tool to gather information that individuals might otherwise be hesitant to provide.
    3. policyIQ’s unique design allows for an anonymous two-way communication between the employee reporting the issue and the designated “agent”. When an issue is submitted, policyIQ generates a random alphanumeric key and encrypts the contents of the issue so that only the designated “agent” can access it. The submitting employee can use that same key to open the issue to read or add follow-up comments.
    4. Board and Management reporting provides a snapshot of issues either by status code (i.e. Open, Closed), or by the “agent’s” name. The reports display the last activity date of each issue to ensure that issues reported are investigated on a timely basis.


If you are interested in learning more about the WhistleBlower module in policyIQ, here are some suggestions to get you started:

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