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Eukleia and Waypoint GRC 'Speaking up about whistleblowing' webinar slides


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Webinar date: 6th February 2019

Whistleblowing systems are a key component of effective compliance programmes. Often mandated by law or regulation, they should be a means of managing and mitigating compliance risk. But whistleblowing systems are only effective if they are used as intended and many companies still struggle with extremely low reporting rates.

In this webinar, we looked at the cultural and technical barriers to driving appropriate use of your reporting hotline. We also offer practical advice, based on real-world experience, about building a ‘speak up’ culture and ensuring that your system is a genuinely effective risk management tool for your business.

Our team of experts and compliance practitioners give practical tips and insights in order for you to get the most out of your whistleblowing system.

Michael Gleave, Global Compliance Officer, Lundbeck
Liz Hornby, Principal Consultant, Eukleia
Paula Davis, Director, Waypoint GRC

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Eukleia and Waypoint GRC 'Speaking up about whistleblowing' webinar slides

  1. 1. Liz Hornby, Principal Consultant, Eukleia Paula Davis, Director, Waypoint GRC Michael Gleave, Global Compliance Officer, Lundbeck Speaking Up About Whistleblowing How to get the most out of your whistleblowing system
  2. 2. Your panellists Paula Davis, Director, Waypoint GRC Michael Gleave, Global Compliance Officer, Lundbeck Liz Hornby, Principal Consultant, Eukleia
  3. 3. What we’ll cover today • What do we mean by whistleblowing? • Challenges for an effective whistleblowing system • Overcoming the challenges – building a speak up culture in practice • Q&A
  4. 4. What do we mean by Whistleblowing? Liz Hornby, Principal Consultant, Eukleia
  5. 5. What do we mean by whistleblowing?
  6. 6. A policy needs a definition “The practice of informing on someone or putting a stop to something.” Collins English Dictionary
  7. 7. What does your policy say? You are concerned that colleague is not following an internal policy. You decide to speak to your line manager about your concerns.
  8. 8. Polling question What did you just do? A. Act like a responsible employee B. Escalate an issue C. Make a report D. Blow the whistle
  9. 9. Definitional factors • Type of wrong doing • Materiality • Organisational involvement • Public interest • Legal/Regulatory • To whom? • Duty/obligation
  10. 10. Polling question What type of duty? A. Legal/Regulatory B. Contractual C. Ethical/Moral D. It is not a duty
  11. 11. Institutionalisation • Growing trend – led by financial services, policing, education, healthcare • Means where an organisation permits, and sometimes requires a whistleblower to use, or at least consider using, internal disclosure channels provided by the organisation before turning to external disclosure channels • A policy needs a definition • Danger of responsibilisation See Vandekerckhove and Commers (2004.p.226)
  12. 12. The whistleblowers’ perspective
  13. 13. • Most whistleblowers see their act as a moral act – a “choiceless choice” • Most whistleblowers raise a concern multiple times before going outside their organisation • Most whistleblowers see themselves as responsible employees, rather than whistleblowers, at least until they go outside their organisation • Many whistleblowers suffer retaliation in practice - many never work again, suffer financial hardship and damage to their health
  14. 14. How?
  15. 15. The act? Line manager Senior Management Whistleblowing Champion/Nominated Person such as a NED Regulator/ Lawyer/ Media Internal Hierarchy External Dedicated Hotline etc. Independent /Quasi External
  16. 16. Key challenges that organisations face in implementing a genuinely effective whistleblowing solution. Paula Davis, Director, Waypoint GRC
  17. 17. The Challenges
  18. 18. 1. Systems 2. Culture
  19. 19. Polling question What channels for reporting misconduct exist in your organisation? 1. Telephone and e-mail reporting to an internal team only 2. External service including telephone and web-based reporting 3. External service including telephone, web reporting and mobile app
  20. 20. The internal ‘hotline’  Shows commitment to listening to employees’ concerns  IF there is someone at the end of the line  Concerns about confidentiality and impartiality can hinder reporting  Systematic case management
  21. 21. The external call centre  Confidence imparted by an impartial third party  Typically includes case management tools  Degree of multilingual support available BUT…
  22. 22.  Deploy multiple reporting channels  Effective language support for ease of reporting  Think mobile  Think apps Things to consider
  23. 23. 1. Systems 2. Culture
  24. 24.  Fear of retaliation  Belief confidentiality won’t be respected  Management involved in the hotline Cultural barriers
  25. 25.  Fear of retaliation  Belief confidentiality won’t be respected  Management involved in the hotline Cultural barriers
  26. 26. “No good deed goes unpunished”
  27. 27. No good deed goes unpunished Fraud Magazine: “Be prepared before you blow the whistle”; Patricia A. Patrick, Ph.D., CFE, CPA, CGFM
  28. 28. No good deed goes unpunished Rates of retaliation have doubled since 2013 Rates of retaliation have risen significantly more than rates of reporting ECI Global Business Ethics Survey 2018
  29. 29. 1. Systems 2. Culture
  30. 30. Implementing an effective whistleblower system: Lundbeck’s journey Michael Gleave, Senior Compliance Officer
  31. 31. ABOUT LUNDBECK We strive for global leadership in psychiatry and neurology by improving the lives of patients Vision Principles We are focused, passionate and responsible For more than 70 years, we have been at the forefront of neuroscience research and our development of pioneering treatments makes a difference to patients worldwide. Key disease areas Depression Schizophrenia Alzheimer’s disease Parkinson’s disease
  32. 32. External factors driving Lundbeck’s hotline setup • Stringent regulations governing pharmaceutical industry • Qui tam exposure • Interactions with healthcare professionals and patients • Value chain complexity involving multiple third parties
  33. 33. Establishment objectives • Increase reporting via a secure channel • Ensure internal and external reporting • Embed a speak up culture • Create a systematic global investigations process Lundbeck’s Compliance Hotline
  34. 34. Lundbeck’s Compliance Hotline setup 0 10 20 30 40 50 2014 2015 2016 2017 2018 Report totals Reports • Established in 2014 • Administered by two employees in Corporate Compliance • A global team of ”case experts” established for investigations • Governed by a global investigation procedure • Oversight in Lundbeck’s Audit Committee
  35. 35. Effective implementation: Lundbeck’s journey Hotline system prerequisites • Latest technology enabling web and app. reporting • Languages need to reflect Lundbeck’s global footprint • End to end secure case management • Data analytics and reporting capability • Simplified data privacy management
  36. 36. Investigation integrity • Robust non retaliation policy which is enforced • Rapid response to Reporters when reporting (<24 hours) • Communicating consequences of misconduct • Protecting the reputation of the Accused • Disclosing hotline statistics in annual report Effective implementation: Lundbeck’s journey
  37. 37. Ongoing awareness is key. Our channels include • CEO town hall • Global management meetings • Regular Code of Conduct training • Local sales meetings • Induction and refresher face to face training • Intranet/Internet landing pages • Coffee machine updates Effective implementation: Lundbeck’s journey
  38. 38. Global investigation complexity • Complex local regulations governing investigations • National privacy requirements • Restrictive labour laws • Regulatory self reporting
  39. 39. Lundbeck’s investigation strategy: 2018-2020  Enhanced case management and hotline system • Leveraging regional compliance officers for investigations and ongoing awareness • Deployment of data analytics in compliance monitoring activities • Application of robotics
  40. 40. We hope you enjoyed the webinar. We’d now like to open the floor for any audience questions. Please submit them in the Questions tab on your navigation panel.
  41. 41. Calls To Action: If you would like to contact us after this event with any follow up questions, please find our email addresses below.