Nowadays, implementing an integrity program should be listed on the C-Level agenda of any business that wants to survive and thrive in the new business world, regardless of size, industry, or activity.
We have seen a number of laws, regulations and standards being enacted with the objective of strengthening corporate governance, especially with regard to the process of combating corruption and fraud.
Within all the necessary requirements for an effective integrity program, the whistleblower channel has a special place. This channel allows greater transparency and creates the possibility that any employee, service provider, suppliers and others stakeholders may report any fact of their knowledge that is in disagreement with the ethics, values and behavior of corporation policy.
Unfortunately, I believe that for the lack of knowledge, corporates in Brazil still do not use this tool in the way they should. Some organizations mistakenly include the whistleblower channel in to the ombudsman, or even with the consumer service channel.
This view is embodied in Kroll's Global Fraud and Risk Report 2016/17, which shows that globally 44% of frauds are identified through the whistleblower channel, however, this same report indicates that in Brazil the whistleblower channel is responsible by only 17% of the findings.
In this report, the whistleblower channel in Brazil ranked at the last position as a fraud detection tool. the most interesting is that the external audit appears in the first place as responsible for 43% of the fraudulent activities discoveries, which does not make any sense.
Well, with the corporate governance maturing processes, aimed at strengthening ethics and values in Brazilian corporations, in the medium-term the perception of the importance of having a robust whistleblower channel in place for the prevention of fraud and acts of corruption should change.
Now, let's look at some attributes of excellence which must be considered for whistleblower channel in order to really fulfill its mission:
- The channel must be available 24 hours, 7 days a week, and can be accessed by different ways by whistleblowers,
- It is best to be operate through an independent company with the technical and professional requirements for proper receipt of the complaint,
- The protection of the whistleblower's anonymity is of utmost importance for the success of the channel,
- There must be a way of exchanging the message with the denouncer, without breaking the anonymity,
- The company contracted to operate the whistleblowers channel must have the technical capacity and knowledge to carry out the first review of the complaint received,
- The complaint received must be sent to at least three different bodies, such as: Legal, Human Resources, fraud prevention or internal audit. It will improve the assurance that all complaints received will be properly dealt with,
- A strong and constant communication and training process should be part of this process so that all employees, service providers, suppliers and others know how to use the channel correctly, without worrying about possible retaliation.
To conclude, the effectiveness of this tool requires an internal environment that is culturally prepared and maturity to understand the ethical values of the organization and consequently the top management has a great responsibility in this regard, since they must be the spokesperson and the example of the integrity program.
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