Speak-up culture toolkit: Leveraging disclosure data to drive a speak-up culture

Disclosure rates reflect company culture. Is yours healthy?

Noshin Khan
Senior Compliance Counsel
January 17, 2023

Photo of two female coworkers speaking by a window overlooking a city

To foster a productive, ethical, trust-driven, and regulation-compliant work environment, organizations are increasingly focused on developing a “speak-up culture.” A speak-up culture extends beyond your whistleblowing helpline to include a culture in which employees feel comfortable making voluntary conflict of interest disclosures.

Disclosures can be used to communicate details about gifts & hospitality, employee/manager relationships, having a second job, sitting on the board of another company, or any other scenario that has the potential to conflict with ethics and compliance policies. Employees are encouraged and expected to disclose such information voluntarily to their employer – and a company with healthy disclosure rates can be confident in their speak-up culture.

But what’s the best way to assess and measure whether a speak-up culture is really in place – and how effective it is at achieving its goals?

Do disclosure rates closely reflect existing policy-related issues? Do employees routinely disclose situations that are potentially in conflict with ethics and compliance policies?  Or is it more common for employees to remain silent?

Improving disclosure rates through employee engagement

Employees may feel uncomfortable about disclosing their own potential conflicts of interest. For instance, they may fear their voluntary disclosure of outside employment will result in retaliation, or a request to cease their outside employment, even though no actual conflict of interest exists and there is no violation of company policy.

A surprisingly high percentage of the time, employees are simply unaware of the disclosure process and how it works. Fortunately, communication and training can help raise awareness of the importance of understanding ethics and compliance policies and following the process for making disclosures.

That’s why forward-looking organizations are striving to go beyond hotlines and bolster their speak-up culture by empowering employees with a holistic ethics and compliance education, including training on disclosures and potential conflicts of interest.

When employees understand that they are the ambassadors of the company values, they feel empowered to represent those values more effectively. They are more inclined to speak up and inspire similar action in others. And over time, the disclosure rates will increase, reflecting a closer measure of existing ethics and compliance policy issues.

Companies that use disclosure software to track this process can then leverage the data generated to achieve many positive outcomes.

Companies can use data insights to:

  • Improve employee awareness of the ethics and compliance disclosure process
  • Ensure employees are comfortable making disclosures — not defensive or afraid of retaliation
  • Increase transparency, better understand risks, identify work locations where they might exist, resolve them more quickly, and reduce legal exposure
  • Monitor employee activity related to disclosures, policies, and training
  • More effectively deter employees from engaging in unethical conduct
  • Empower workforce leaders while ensuring the appropriate guardrails are in place
  • Recommend areas of communication and training to strengthen a speak-up culture and positive work environment

More communication means more engagement and a better culture

Let’s consider this last area in particular: communication and training.

If employees aren’t knowledgeable about, or perhaps not even aware of, the organization’s ethics and compliance policies and procedures, disclosure rates will stagnate. As a result, the company’s ability to resolve issues, build trust, and ultimately generate a self-sustaining speak-up culture will be limited.

That’s why it’s important to engage employees from the moment they join the company and on a regular basis thereafter. Beyond the usual training – which ideally should be made as frictionless and fun to experience as possible – organizations should also have targeted training sessions for employees whose job roles are more likely to involve potential ethics and compliance risks. Using multiple channels like newsletters, in-person training sessions, real-time chat services or applications, and e-mail to ensure employee awareness and engagement will help build a speak-up culture.

Once employees are aware of ethics and compliance policies and procedures, overall engagement with making disclosures will noticeably increase. Also, the portal will generate data that, once analyzed, can point to areas of improvement regarding hidden areas of employee concerns, evolving issues, or the types of problems that might otherwise go unresolved and unaddressed.

And over time, the organization can leverage ongoing analyses to drive a cycle of continuous improvement, minimizing the likelihood of issues going unreported and maximizing the trust necessary for a speak-up culture to exist.

How OneTrust can help

For more information on this and related COI issues, and the power of a speak-up culture to help organizations manage risk, build trust, and substantially enhance the work environment, download our e-book, which contains a step-by-step guide to raising COI policy awareness and improving reporting rates.

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