Global Anti-Bribery Guidance

Best practice for companies in the UK and overseas

15. Speak Up & Advice Channels

Quick Read

Speak up and advice channels are for employees and others to seek advice and raise concerns about issues, including bribery.  Speaking up or, as it is sometimes called, whistleblowing, has brought to light many significant bribery cases.  

Advice channels allow employees to clarify policies, and receive guidance about how to handle sensitive situations.   Such channels are most effective when there is a strong corporate culture of integrity so that employees trust that requests for advice or speaking up will be handled promptly, thoroughly and fairly.  Advice can be given in many ways and the company should explore and develop an integrated range of routes by which employees can receive support.

Key elements of best practice

  • Open culture: Build a culture of trust so that employees feel able to seek guidance or discuss issues with their managers or the relevant support functions and are  confident to use speak up channels if they feel this is necessary.
  • Provide a range of channels: Create a range of ways for employees to seek guidance. In addition to a hotline, companies should encourage discussions with line managers, or encourage management to have an open door policy.  Opportunities to meet with compliance officers, personnel managers or relevant networks of employees should also be created.
  • Proper treatment: Ensure that those who speak up are not harassed or penalised, but recognised or rewarded for their efforts.
  • Promptness: Deal with matters raised promptly. Check case closure times as delays can weaken employees' trust in the process and the company’s commitment to integrity. Delays may also have legal consequences.
  • Complete the process: Ensure that every case follows the relevant process through to conclusion and that the employee is thanked for their commitment to upholding standards in using the channel. If possible employees should be asked to comment on their satisfaction with the process, although it should be noted that not every case will reach an outcome sought by an employee.
  • Analyse: Monitor and analyse the use of advice and speak up channels as they can provide early warning signs, such as that the bribery programme may need attention. Capture data from all channels used to seek advice including discussions with management, compliance, HR and other functions.