Lessons from the Conference: Whistleblowing: Moving from compliance to a cultural approach

Electronic Crime and Corporate Transparency Bill

Whistleblowing is a key means by which organisations can be held to account, but it comes with significant risks both for the whistleblower and for the organisation concerned. Kate Sayer, Director of Integrity and Ethics at Oxfam, has spearheaded a new approach to whistleblowing, complaint procedures and integrity at the charity. Oxfam was still dealing with the aftermath of the 2018 Haiti scandal when she joined in 2020. She gave a keynote speech about her experience at our Annual Conference, Governance 2023.

Rather than a focus on the misconduct of a handful of individuals, Sayer emphasised the importance of thinking about integrity systemically. What are the indicators of an ethical culture, one in which people can trust an organisation? How can employees at all levels be encouraged to do the right thing, in the right way? Where is power held within an organisation?

At the heart of these questions is the difference between a compliance approach and a cultural approach to organisational integrity. On the one hand, a compliance approach looks at the policies and procedures which are in place. These may include codes of conduct, zero tolerance statements, training sessions for employees, complaints procedures and disciplinary measures.

On the other hand, a cultural approach looks at building trust in an organisation. Though it rests on the same policies that a compliance approach requires, it goes beyond these and aims to address – and even change – the behaviour of people within an organisation. Key hallmarks of an effective cultural approach to integrity include: a clear tone from the top; managers who lead by example and who are open to hearing bad news; a desire to learn from mistakes; and taking swift, fair action when issues come to light. Fundamentally, a cultural approach means that policies and procedures are embedded into day-to-day practices – rather than purely a tick-box exercise or a once-annual email reminder.

According to research brought to light by Margaret Heffernan in her book Wilful Blindness, 85% of employees who have concerns do not report these or “blow the whistle”. This inaction can stem from a fear of reprisal, an unwillingness to (be seen to) betray their colleagues, and a doubtfulness that they will be believed or that raising a concern will make any difference. Despite the low levels of people who report, Heffernan reports that, amongst those who do, the majority act in the interest of their organisation and are not malicious – although complaints may be based on one person’s individual experience rather than being wholly representative.

If the majority of complaints are genuine, how then can organisations create a transparent culture where people are able to speak up? The first step comes down to the issue of belief – ensuring that concerns are treated with respect and fairness rather than dismissed. The second is about taking meaningful action to address concerns and, where possible, to resolve them. The third is being proactive in listening and opening up space for people to raise suggestions and issues, rather than waiting for people to speak up or relying on whistleblowing, which itself tends only to happen when issues have become far larger than they may have otherwise done with more rapid intervention. One route to achieving this is through employee engagement mechanisms such as town halls and staff surveys. The final piece of the puzzle is in supporting senior leadership through training and facilitation, which can equip them in how best to listen out for, and to handle, any issues raised. To be truly systemic, all of these steps need to be taken in full awareness of the organisational and interpersonal context.

Emily Ford, Policy Adviser at CGIUKI

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