Hot News

HOTLINES, PROACTIVE OR REACTIVE?

Andrew H. Joseph, J.D.

Formerly, organizations adhered to the rule, "If it isnt broken, dont fix it." But crisis managers are now strongly advising "If it isnt broken, look for the cracks before they get too large to fix." Recent examples of how adherence to this rule could have saved organizations from serious difficulties abound-- the U.S. Army, Texaco, and Mitsubishi. And in the case of the Army, that crack quickly turned into a canyon.

At the Aberdeen Proving Ground in Maryland, the Army set up a hotline to field calls related to the allegations of rampant sexual abuse at the facility. In the first six days of its operations, the special Army hotline received over 2,000 calls relating sexual misconduct in the service. One of the officers tasked with answering the hotline stated that people were "calling from all over," including a few calls from the Navy and Air Force. Callers identified incidents which had occurred in the last five years, however, some of the calls even dated back 10 to 20 years. The Army brass is quickly finding that its problems are not isolated to Aberdeen. Of the 145 calls deemed serious enough to warrant investigation, 89 involved bases other than Aberdeen. Of course, the lesson that the Army is learning the hard way is that the cracks have existed for a long time. The question then is how can organizations effectively flesh problems out in their infancy so that they can be appropriately addressed.

The U.S. Sentencing Commission Guidelines for Organizations provides parameters for an acceptable corporate compliance program. The Guidelines strongly advise that organizations establish "a reporting system whereby employees and other agents could report criminal conduct by others within the organizations without fear of reprisal." This advice translates into a hotline, a vital component of any corporate compliance program.

At the Pillsbury Corporation in Minnesota, a hotline was established to field calls from employees regarding their concerns and suggestions. Of course the dichotomy here is that the Army hotline was reactive, while the Pillsbury line was proactive. Increasingly, hotlines are becoming the vehicle of open communication in government and corporations. The effective and timely implementation of a hotline will give an organization the opportunity to address issues before they balloon into serious institutional problems.

The hotline established by Pillsbury is indicative of organizational efforts to head off potential problems. Lou de Ocejo, Pillsburys personnel chief, stated that by giving employees the chance to end-run the chain of command, the system exposes inefficiencies and potential problems. He stated that, "The number one objective for the senior management of this company was to have employees in our face." Improving communication in order to identify problems is the ultimate goal of an effective hotline.

But Pillsbury found that even when management solicited feedback, employees were not responsive. The overwhelming fear is, once an employee lodges a complaint or criticism, they will be retaliated against. Therefore, the non-retaliation policy is not only a recommendation of the U.S. Sentencing Guidelines, it really is the driving force behind a successful hotline.

Employees calling a hotline are usually tentative and suspicious. Often they fear that their call may be traced or that management will somehow identify them. In order to alleviate these concerns, employees should understand how the hotline operates. Employees should be informed if an outside firm is operating the hotline because many are comforted knowing that an unbiased party is receiving and reporting their calls. If the calls are handled internally, management should describe the steps taken to ensure confidentiality of the callers. By understanding the function and operation of the organizational hotline, employees will be more apt to report issues and concerns.

A hotline is an effective tool for organizations actively working to identify and correct the problems that may plague their ranks. However, recent lessons show that the timing of the hook-up of your Hotline is crucial.
Now is better than later.

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