Effective speak-up arrangements for whistle-blowers

Full text

Effective speak-up
arrangements for
whistle-blowers
A MULTI-CASE
STUDY ON
THE ROLE OF
RESPONSIVENESS,
TRUST AND
CULTURE

This report explores the
variety of arrangements
for speaking up in
the public and private
sectors. It takes the
viewpoint of those
who develop, operate
and oversee such
arrangements, and
seeks to provide
recommendations for
an effective framework.
© The Association of Chartered Certied Accountants
May 2016
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Effective speak-up arrangements for whistle-blowers:
A multi-case study on the role of responsiveness, trust and culture
Dr Wim Vandekerckhove
Prof Dr Marianna Fotaki
Dr Kate Kenny
Ide Juang Humantito
Didem Derya Ozdemir Kaya

4
WIM VANDEKERCKHOVE
Wim Vandekerckhove holds a PhD in applied ethics from Ghent University (Belgium). He is Principal Lecturer in
organisational behaviour at the University of Greenwich and teaches business ethics. His recent co-edited Labor
and Global Justice (2014, Routledge), and International Research Handbook on Whistleblowing (2014, Edward
Elgar) and regularly contributes to journals. He advises on whistleblowing to organisations, including Transparency
International, Public Concern at Work, the Whistleblower Advice Centre (the Netherlands), the UK Department of
Health, and the Council of Europe. He currently collaborates in whistleblowing research projects with Universite
Paris Ouest Nanterre (France) and Grifth University (Australia).
MARIANNA FOTAKI
Marianna Fotaki is Professor of Business Ethics at Warwick Business School and a visiting professor at The University
of Manchester. She graduated in medicine/public health and holds a PhD in public policy from the LSE. Before
joining academia, she has worked as a medical doctor for humanitarian organizations including Médecins Sans
Frontières. Marianna has published over 45 papers on the marketization of public services, health inequalities,
gender in organisations. She co-edited The Psychosocial and Organization Studies (Palgrave, 2014) with Kate
Kenny. Marianna co-directs pro bono a think tank Centre for Health and the Public Interest (http://chpi.org.uk).
KATE KENNY
Kate Kenny is a Reader in Management at Queen’s University Belfast. She researches culture and identity in
organisations and is interested in theories of affect, power and psychoanalysis. She is a research fellow at Judge
Business School (Cambridge University) and previously was an Edmond J. Safra Lab Fellow (Harvard University).
Her current whistleblowing projects are funded by ESRC, the British Academy/Leverhulme Trust, ACCA and
Harvard University. She has published in journals including Organization Studies and Human Relations. She recently
published Understanding Identity and Organizations (Sage 2011, with A. Whittle and H. Willmott), and Affect at
Work: The Psychosocial and Organization Studies with Marianna.
Lead researchers

This research project examined the
opportunities, challenges and best
practices associated with different types of
speak-up arrangements, both internal and
external, in a variety of organisational
settings across different sectors, industries
and locations.
While recent research on the topic has
focused mainly on the experience of
those who have ‘blown the whistle’,
the approach used here explored
arrangements for speaking up (‘speak-up
arrangements’) from the viewpoint of those
who develop, operate and oversee them,
seeking to provide recommendations for
an effective framework.
Findings from the investigation show that
effective speak-up arrangements:
• involve a combination of different
channels through which employees
can voice a concern
• contribute to building trust through
speak-up practices that evolve over
time and are supported by the
independence of speak-up operators
• rely on robust and consistent response
systems that are supported by
appropriate recording of speak-up
events, coordinated follow-up activities,
and willingness to respond at different
management levels; there are
nevertheless barriers to responsiveness
caused by anonymous concerns, legal
issues, and lack of a visible response,
albeit inadvertent, and
• may need to take into account the
potentially difcult interactions between
organisational and national cultures.
These ndings give rise to key
recommendations for developing,
operating and overseeing effective
speak-up arrangements. These are further
discussed in the ‘Recommendations’
section at the end of this report.
1. Provide a variety of voicing channels
and consider the use of an external
independent advice channel when
introducing a speak-up arrangement.
2. Be prepared to accept that concerns
received may not be strictly considered
speak-up or whistle-blowing cases but
some of them may nonetheless help
organisations recognise previously
unidentied risks.
3. Design a speak-up ‘back ofce’ to
record concerns and use this data to
strengthen risk management and
response processes, investigation and
intervention, acknowledging the variety
of concerns that could be raised.
4. Ensure that responsiveness is well
organised, clearly mandated and
adequately resourced. Merely
encouraging employees to speak up,
without putting robust response systems
in place, is likely to have negative
consequences, for both employees and
the organisation.
5. Make responses visible where possible.
This may be achieved by exploring
whether employees who raised a concern
can be included in developing a solution
to the problem; this in turn can contribute
to developing collective sense-making
and increase trust in the effectiveness of
the speak-up arrangement. It is also
important to emphasise continuously to
managers at all levels that responding
to concerns is part of their role, and to
restrict their discretion about whether/
how to respond.
6. Consider participating in the
development of a standard for the
public reporting of data from speak-
up arrangements.
Specic recommendations to
directors and managers are available
from the ACCA website at
www.accaglobal.com/whistleblowing
Executive summary 5
Effective speak-up arrangements
involve a combination of
different channels and a robust
response system that contribute
to building trust within
organisations.

Contents
1. Introduction .........................................................................................................7
2. Methodology .......................................................................................................8
3. Combining different channels ....................................................................... 10
3.1 Internal channels .......................................................................................10
3.2 External channels ......................................................................................10
3.3 Digital channels ......................................................................................... 12
4. Trust as a process ............................................................................................ 13
4.1 Time ............................................................................................................13
4.2 Independence ...........................................................................................14
4.2.1 Specialist speak-up operators ......................................................... 14
4.2.2 Rule-bound referrals.........................................................................14
4.2.3 External independent advice ..........................................................15
5. Responsiveness ................................................................................................ 16
5.1 Recording speak-up events ...................................................................... 16
5.2 Liaising functions and division of labour ................................................. 17
5.3 Making responding the norm...................................................................18
5.4 Barriers to responsiveness ........................................................................18
5.4.1 Anonymity concerns .........................................................................18
5.4.2 Legal issues ....................................................................................... 19
5.4.3 Invisibility of the response ............................................................... 19
5.5 Facilitators of responsiveness...................................................................19
6. Using speak-up data ....................................................................................... 21
6.1 Pattern recognition ...................................................................................21
6.2 Data for training purposes ........................................................................21
6.3 Publishing aggregated speak-up data ....................................................21
7. Interactions with culture ................................................................................ 23
7.1 National cultures .......................................................................................23
7.2 Organisational cultures ............................................................................. 23
7.3 Language ...................................................................................................24
8. Conclusions ....................................................................................................... 25
9. Recommendations ........................................................................................... 26
References ............................................................................................................. 27

7
This research project examined the
opportunities, challenges and best
practices associated with different types
of speak-up arrangements, both internal
and external, in a variety of organisational
settings. Qualitative research was
undertaken with people operating the
speak-up arrangements in a health care
organisation (an NHS Trust in the UK),
a multinational bank, a multinational
engineering company, and a central
government in South East Asia.1 The
research focused on:
• improving understanding of the
distinctions between internal and
external channels through which
employees can voice their concerns
• identifying key challenges for effective
speak-up policies by providing evidence
of how to overcome practical limitations
of these channels
• understanding the opportunities and
best practices associated with effective
speak-up arrangements, enabling
cross-sector learning by drawing on
experience from banking and nance
as well as public health services and
public and private sectors in different
cultural settings.
Whistle-blowing forms a key means of
addressing dangerous wrongdoing and
dysfunctional behaviour in today’s
organisations. The absence of effective
speak-up arrangements prevents
organisations and societies from avoiding
major disasters (Devine and Maassarani
2011). For this reason, whistle-blowing has
become an important issue, both for
societies and for organisations, and
attempts to alert the authorities to
wrongdoing by internal personnel have
been increasing.2
In many cases, suffering and retaliation
experienced by whistle-blowers are
exacerbated because few, if any,
procedures are in place to receive and
follow-up concerns raised by employees
(Alford 2011; Devine and Maassarani 2011).
Speak-up arrangements can have
economic benets for organisations and
society. Whistle-blowing is important from
a societal and an ethical perspective, but it
also saves money both for private and
public sector organisations. A recent study
of over 5,000 rms shows that 40% of
companies surveyed suffered from serious
economic crimes that averaged over $3m
each in losses (Devine 2012). Whistle-
blowers exposed 43% of these crimes,
which means that whistle-blowing was
more effective than all the other measures
combined: corporate security, internal
audits and law enforcement.
Workers who voice their concern can help
to prevent the dysfunctional behaviour that
leads to nancial and reputational losses
by rms and public sector organisations.
Ineffective speak-up arrangements, by
contrast, deny organisations and
institutions an opportunity to address the
wrongdoing that whistle-blowers perceive,
early on in the process, and thus lose time,
money and effort along with protracted
and unnecessary legal battles.
The question of how to develop effective
speak-up arrangements has become
urgent. Media attention on whistle-blowing
cases has increased, and policymakers
across the world are being pressured to
pass legislation protecting whistle-blowers
(Vandekerckhove 2006; Devine 2015).3
While legislation is essential for
encouraging speaking up against
wrongdoing, it has also drawn attention
to its connection to the organisation and
the particular arrangements it can, but
often fails to, put in place to facilitate
effective speaking up.
Implementing effective speak-up
arrangements is now part of reforming
corporate governance, public sector
accountability and professional
responsibility. It is hoped that this report will
contribute to the success of these reforms.
1. Introduction
Having whistle-blowing
arrangements contributes
to sound risk management
but developing a culture of
speaking-up remains the key
challenge for organisations.
1 The research was funded by ACCA and the ESRC, and was approved by the University of Greenwich Research Ethics Committee (ref UREC 14.4.5.13).
2 In health care, for example, whistle-blowing to the media led to the Public Inquiry into the Mid-Staffordshire Hospital Trust, and an enduring stream of NHS whistle-blower
cases triggered the Freedom to Speak Up Review in 2015. In the wake of the nancial crisis, in the US the Securities and Exchange Commission (SEC) received 3,620 cases
through whistle-blower disclosures in the scal year 2014, up 10% from 2013, and 21% compared with 2012. In the UK, the Financial Conduct Authority (FCA) received
1,040 cases from whistle-blowers in 2013, an increase of 60% compared with the year before (see SEC 2014 and FCA 2014).
3 Also see Council of Europe (2014).

8
In the past, research into whistle-blowing
mainly took the viewpoint of the whistle-
blower, leading to critical improvement in
legal protection in countries such as the UK
(Vandekerckhove et al. 2014a). Looking at
speak-up arrangements in four
organisations (both private and public)
covering ve continents (Africa, Europe,
Latin America, North America, and Asia),
the research presented here takes the
viewpoint of those who develop, operate
and oversee speak-up arrangements, to
provide practical recommendations for
policymakers and organisations.
The research was conducted in three
stages. The rst, preparatory, stage was
a desk study of relevant literature, policy
documents and professional publications
on internal procedures for voicing
concerns about wrongdoing. This was
followed by interrogating existing data
from interviews with whistle-blowers from
health care, nancial services and defence
contracting services (n=56) with the aim of
identifying key characteristics of ineffective
speak-up arrangements.
In the second research stage, primary data
was collected from four organisations
(described in more detail below) through
semi-structured interviews, carried out face
to face and over the phone with speak-up
operators such as compliance ofcers, HR
ofcers and directors, legal counsel,
investigators and auditors (n=26). It also
proved possible to use documents from
the four organisations, such as annual
reports, whistle-blowing policies, and
intranet screenshots. The analysis of the
interview data started during the data
collection period (November 2015–January
2016). A researcher not involved in the
interviews used Nvivo to conduct open
thematic analysis of the interview
transcripts. Initially, 120 themes were
coded, which were collapsed into 76
themes, and 22 groups of themes. The
research team held weekly discussions to
develop the within-case analyses. This led
to a further short round of primary data
collection through interviews with external
speak-up operators and advisers (n=6): a
speak-up consultant, a hotline operator, an
external ombudsman, an independent
advice line, a law rm, and a regulator.4
The third stage of the research consisted of
a cross-case comparison to identify
common threads, key themes and topics.
Preliminary ndings were presented to
three stakeholder audiences: ACCA
members, compliance and ethics ofcers,
and whistle-blower support groups.5 This
involved a short presentation of the
research aims and preliminary ndings, and
moderation of a Q&A-driven discussion, of
which notes were taken. These were used
to assist the researchers in arriving at the
ndings and recommendations presented
in this report.
ORGANISATION 1: THE NHS TRUST
As a National Health Service Trust this
hospital is a public sector corporation,
treating more than 200,000 patients a year.
It is located in the Northwest of England.
Three years ago the organisation had a
number of experiences where employees
raised concerns with a regulator and the
press. Managers acknowledged that they
had not acted fast enough or had not
communicated well enough with the
employees who had raised the concern.
A speak-up arrangement was developed
consisting of different channels with various
levels of condentiality and independence
and various communication interfaces.
ORGANISATION 2: THE BANK
This bank is headquartered in Northwest
Europe. It provides a range of services
to personal, business and corporate
customers. Its branches are predominantly
in Northwest Europe, but there is also a
presence in the US.
The organisation has had a speak-up
channel through its compliance function
since the early 2000s. In 2012 the board
requested a review of how the organisation
facilitates its employees in raising a concern.
This decision was made in response to
changes in regulation on whistle-blowing,
as well as a desire to change the approach
to speaking-up from policing towards
engagement. HR at group level took over
the coordination and developed a speak-
up arrangement that includes direct and
indirect communication channels, as well
as an external independent advice channel.
2. Methodology
Qualitative research was
conducted in various
organisational settings across
different sectors, industries
and locations.
4 These were Speakout Speakup, Expolink, Rohde-Liebenau RCC Risk Communication, Public Concern at Work, Global Practice Head Employment and Incentives at
Linklaters LLP, London.
5 ACCA members on 21 January 2016 at ACCA London; ethics and compliance ofcers at the European Business Ethics Forum (EBEF) on 29 January 2016 in Brussels;
whistle-blower support group representatives on 22 March 2016 at the University of Greenwich in London. Participants in the latter workshop were: Wendy Addison
(whistle-blower and trainer through Speakout Speakup), Anna Meyers (Government Accountability Project, Washington DC), John Devitt (Transparency International
Ireland), Colin Leys (Centre for Health and the Public Interest), and Georgina Halford-Hall (Whistleblowers UK).

ORGANISATION 3: THE ENGINEERING
COMPANY
This is one of the world’s largest
engineering rms, with more than 300,000
employees. It is active in more than 180
countries, in diverse sectors such as power
generation and transmission, transport,
and medical imaging.
In the mid-2000s the company went
through a crisis, triggered by a number of
bribery scandals that were exposed in the
media. Top management was replaced.
Under the new CEO a compliance
organisation was created at group level.
The number of employees in specialist
compliance functions grew tenfold. A
speak-up arrangement was developed
comprising IT-based internal channels, an
externally operated hotline and an external
ombudsperson. The organisation made
these channels accessible in many
languages and devised procedures and
protocols for a systematic processing and
follow-up of employee concerns.
ORGANISATION 4: THE CENTRAL
GOVERNMENT
This is a central government of a country in
South East Asia. The country is in the top
30 of countries by GDP.
At the end of the 1990s an anti-corruption
law was enacted, and in the early 2000s
an anti-corruption commission was
established. Recognising the importance of
individuals who speak up about corruption
that they witness, the government passed a
witness protection law. The legislation did
not, however, protect whistle-blowers from
workplace retaliation. To mitigate this, a
guideline was issued for developing a
speak-up arrangement in government
agencies. This arrangement is currently
being implemented in state institutions,
government agencies and local
governments. Civil servants can raise a
concern with a special administrative unit
designated to receive whistle-blowing
information, and to monitor and report
the progress of investigations to the
minister and the whistle-blowing
employee. A separate audit unit analyses
the information and carries out the
investigations. Another separate unit
decides on sanctions for wrongdoers.
9Effective speak-up arrangements
for whistle-blowers
2. Methodology
Two of the organisations
studied introduced their
speak-up arrangement in
response to an internal
crisis; two did so after
legislative changes.

10
Speak-up arrangements in the four
organisations participating in this study
comprised various combinations of voice
channels.6 Respondents from all
organisations saw direct and verbal voicing
of concerns with the line manager as the
ideal arrangement. Even so, they also
acknowledged that this might not always
be, or at least be perceived to be, the most
effective way of voicing concerns. A brief
description of the channels is given here,
with an overview of the how these channels
exist in each organisation in Table 3.1.7
3.1 INTERNAL CHANNELS
There were three types of internal channels
among the participating organisations:
question channels, internal hotlines, and
key internal persons. Some of these provide
information as well as voicing mechanisms.
Two organisations, the NHS Trust and the
engineering company, provided question
channels through which employees could
ask management whether something of
concern to them actually constituted
wrongdoing or not. In the engineering
company the compliance function would
provide answers directly to the voicing
employee, whereas in the NHS Trust the
CEO coordinated the answers and published
an anonymised version on the Trust’s
intranet, accessible to all staff members.
The NHS Trust operated internal hotlines in
combination with the question channel.
Allegations of wrongdoing voiced through
that channel were referred for investigation
and followed a separate response route.
Hence, the NHS Trust operated an internal
hotline as a combined route for voicing
concerns, whether as questions or
allegations. Additionally, the CEO
personally responded to the letters and
emails received directly from a voicing
employee, but these conversations might
also have appeared anonymously on the
intranet, where appropriate. The bank
provided employees with a toll-free phone
number, and operated this hotline internally.
All four organisations also listed key
internal persons with whom employees
could raise a concern. In the bank these
were the CEO, chairman, HR director, head
of internal audit, chief risk ofcer, and head
of compliance. In the NHS Trust, in
addition to the CEO, these were a non-
executive director, counter-fraud ofcer,
and the director of nance. In the
engineering company, they included local
compliance ofcers and regional
managers. In the central government
speak-up arrangement the key persons
were the respective heads of the
government agencies and the minister.
3.2 EXTERNAL CHANNELS
There appeared to be considerable
differences between external channels.
An externally provided hotline is an
extension of the company’s internal
channels: such hotlines are externally
operated, but concerns received are
transmitted back to whoever oversees
the speak-up arrangement within the
company. An external ombudsperson,
usually a lawyer, passes on information
from the voicing employee to top
management (with permission of the
employee), while making the necessary
arrangements to follow up how both the
concern and the voicing employee are
handled. The level of autonomy for the
voicing employee is greatest with external
independent advice operators. Their
advice to the voicing employee is covered
by legal privilege and their client
relationship is with the voicing employee.
Call centres operated by an external hotline
provider operate with a script of questions
aimed at getting the information required
to evaluate the concern and investigate
further. External hotline providers also
provide digital chat-rooms that allow
two-directional anonymous communication
between voicing employees and company
compliance ofcers. External hotline
provision does leave some autonomy and
choice with the voicing employee. Call-
3. Combining different channels
Effective speak-up arrangements
involve a combination of
different channels through which
employees can voice a concern.
6 In the literature, ‘employee voice’ denotes different ways in which employees express ideas or opinions in order to inuence practices and decisions in organisations.
While there are academic discussions around different typologies of voice, in which whistle-blowing is a particular type of voice (justice-oriented voice), there are also
perspectives emphasising commonalities of different types of voice (see Mowbray, Wilkinson and Tse 2015)
7 It must be noted that the voicing of concerns to a union or the regulator was not within the scope of this research. A union should always be able to give an employee
advice on how to raise a concern and even be a source of support, but only the NHS Trust explicitly lists this route. There is also no ‘contracting’ between a union and a
company, and in this sense unions, like regulators, are not part of speak-up arrangements. Unions or regulators are therefore not included in this discussion of speak-up
arrangements. There is, howev-er, literature that argues that unions should be part of speak-up arrangements (see Lewis and Vandekerckhove 2016 and Van-dekerckhove
and James 2013).

11Effective speak-up arrangements
for whistle-blowers
3. Combining different channels
centre operators tell callers the person to
whom they will pass on the voiced concern,
at which stage callers can still decline the
transmission of their concern. With digital
anonymous chat-rooms the voicing
employee is able to end the
communication and ‘disappear’ at any time.
The engineering company used a hotline
operated by an external provider.
Concerns raised were fed back to the
central compliance team at headquarters.
Consideration for deciding on this approach
included coverage of different languages
by the provider, its 24–7 accessibility, safety
considerations, and data protection. In the
central government special agencies were
created that were independent of other
government agencies, to receive and
investigate concerns.
An external ombudsperson is usually a
lawyer, but there are many models of
ombudsperson systems. Usually, the
ombudsperson will only pass on
information from the voicing employee to
top management with permission of the
employee. The ombudsperson will also
make the necessary arrangements to follow
up how both the concern and the voicing
employee are handled.
Ultimately, however, the ombudsperson acts
for the long-term interest of the organisation.
An ombudsperson is an ‘inside–outsider’
working under strict condentiality and
neutrality. In the long-term they can help to
develop the effectiveness of a speak-up
arrangement. A silenced concern or
retaliation against a voicing employee is
a risk to the company’s integrity. In the
short-term the ombudsperson can facilitate
alternative dispute resolution when other
speak-up channels prove ineffective. The
engineering company had contracted an
external ombudsperson.
The bank and the NHS Trust had
contracted an external independent advice
line where employees could seek advice on
how to voice their concerns in the most
effective way, and within the boundaries of
legal whistle-blower protection. Both the
bank and the trust used a registered legal
advice centre, whose advice to the voicing
employee is covered by legal privilege.8 In
contrast with an external ombudsperson,
an external independent advice operator
has a client relationship with the voicing
employee and offers advice in the
employee’s interest.
Although they explore possibilities for
internal voicing rst, external independent
advice lines can and do advise and guide
voicing employees to regulators. They also
inform employees about their rights and
avenues under the whistle-blower
protection legislation. They differ from
external hotline providers in the sense that
the default position is to help the
employee to identify the most effective
way of voicing a concern. Only
exceptionally, and always on request from
the employee, will they voice to the
organisation on behalf of the employee.
There are considerable
differences among both
internal and external
speak-up channels.
Informal Question
channel
Key internal
persons
Internal
hotline
External
hotline
External
Ombuds-
person
External
independent
advice
NHS Trust X X X X X
Bank X X X X
Engineering company X X X X X
Central government X X X
Table 3.1: Speak-up arrangements as combinations of voice channels in four organisations
8 For both these organisations this was Public Concern at Work (UK).

3.3 DIGITAL CHANNELS
The speak-up arrangements in the four
organisations included voice channels that
made use of digital technology. In addition
to a telephone interface, internal and
external hotlines also used email and
Web applications. At the time of writing,
the engineering multinational was
conducting a trial in a number of countries
with a telephone hotline that uses
automated voice handling instead of ‘live’
staffed call centre. Some of the internal
key persons in the central government
speak-up arrangement used smartphone
apps as a channel for employees to raise
a concern. The Institute for Business Ethics
has also launched an app that can be used
as a question channel (Institute for
Business Ethics n.d.).
One interviewee saw the advantages of
speak-up apps as follows:
‘Those apps are becoming
increasingly sophisticated, and
of course, one of the advantages
of the app or mobile technology
is, number one, people are very
likely, irrespective of where
they’re located in the world, to
have mobile technology and,
number two, you can deal with
language barriers.’
(Interviewee R)
Socio-technological innovation for speak-
up channels has only just begun. The
implications of these innovations for the
effectiveness of speak-up arrangements
are still unclear.
12Effective speak-up arrangements
for whistle-blowers
3. Combining different channels
The use of digital
technology for speak-
up channels has only
just began and it is too
early to measure its
implications.

Underlying trust is important for effective
and safe whistle-blowing procedures
(Holtzhausen 2009, Near and Miceli 1995).
The research demonstrated that rather
than relying on the level of trust already
present in the organisation, speak-up
arrangements can in fact increase internal
trust. This is because developing trust is a
continuous process involving practices that
change over time and that are supported
by the independence of speak-up
operators but, in some cases, can be
undermined by external factors.
Three of the organisations studied had
introduced their speak-up arrangement
in response to a crisis of trust. In the
engineering company this crisis was
triggered by wrongdoing involving the
organisation, which had led to substantial
media attention, regulatory sanctions,
and wide-scale police interventions. In the
NHS Trust regulators carried out
inspections after a concern was directly
raised with them. In the bank, widespread
scandals in the industry also affected trust
in their own organisation.
None of these organisations had time
to rebuild trust before implementing
a speak-up arrangement. Instead, each
rebuilt it through implementing such
an arrangement.
4.1 TIME
Speak-up arrangements can change the
level of trust in organisations over time.
The organisations studied differed in the
time needed to implement speak-up
arrangements.
Over a decade ago, the engineering
company introduced its speak-up
arrangement, comprising multiple channels
(section 1.1 above) to voice concerns. This
was part of an organisational overhaul of
the compliance function, which was
centralised to have more independence
from operational matters. The number of
compliance ofcers grew tenfold. While
initially the question channel was used the
most, the company saw more employees
raising a concern through the externally
operated hotline over time. Over time,
in most of the regions where it operates,
voicing employees started to use open
and direct communication more frequently.
Hence there was a shift in the channel
preferred by employees: from an initial
preference for asking integrity-related
questions through a Web interface to a
preference for directly raising a concern.
It is possible that familiarity and positive
experiences with one channel transfers
trust to other channels, in this case
between past experiences to future
experiences (Nooteboom 2006). The
increased resourcing and change in the role
of the compliance function could also have
helped develop trust within the company.
Development of trust can also be initiated
by changing the ‘tone at the top’. The
research showed an evolution in how
management can cultivate trust through
speak-up arrangements. The bank moved
the oversight of the speak-up arrangement
from the compliance function to the HR
function at the group level, to support a
change of ‘tone’ about speaking up and
widen the scope of concerns taken into
account, while emphasising the well-being
and engagement aspect of speak-up rather
than portraying it as ‘policing’. At the same
time, the organisation started to promote
an additional channel through which
employees could get free and
independent advice on how to raise a
concern and how the law protects them.
These changes to how people trust the
speak-up arrangements corresponded with
changes in the professional identity of
those who operated these arrangements.
Compliance ofcers from the bank and the
engineering company noted that the
speak-up arrangement had changed the
employees’ perception of them. While they
used to be ‘police’, they now said they were
seen more as ‘someone who can help’.
4. Trust as a process 13
Rather than relying on the
level of trust already present
in the organisation, speak-
up arrangements can in fact
increase internal trust.

4.2 INDEPENDENCE
The secondary interview data indicates that a
lack of independence of speak-up operators
leads to ineffective whistle-blowing and a
general distrust of top management.
This resonates with the primary interview
data with speak-up operators: they argued
that their level of independence from
day-to-day operational matters gave them
status as trustworthy professionals.
‘…one of the advantages that we
have with my role [is that] I’m
not a business partner. So if you
were running this through the
HR business partners, they’re a
little bit too close. Whereas I’m
not aligned to any one of the
individual business teams, so that
gives me the added opportunity
to be more independent.’
(Bank interviewee K)
4.2.1. Specialist speak-up operators
As receiving and following-up speak-up
concerns is their primary task rather than a
marginal aspect of their job description,
specialist operators tend to focus on
appropriate listening, objective evaluation
of the quality of investigations, and
carrying out and documenting the end-to-
end following-up of concerns. They are
also able to spot potential wrongdoing
underlying concerns that at rst sight
seemed insubstantial or unfounded.
Interviewees gave examples of concerns
that would have been ignored before the
speak-up arrangement was in place, but
were now looked into as a result of
involving specialist operators. There were
also examples where the compliance
function had initially referred a concern to
the specialist HR speak-up operator
because they believed it had no
compliance-related content. Subsequently,
the HR operator identied issues that had
relevance for compliance that were not
initially mentioned by the employee.
In all the organisations, interviewees noted
that at least half the concerns raised
through speak-up channels were not about
wrongdoing in the sense of harm to the
public interest, breach of regulation, or
breach of organisational policy. Specialist
speak-up operators tend not to disregard
such concerns as an ‘employee grievance’
or just a nuisance. Instead, they are able to
perceive what seem at rst sight to be
people-related concerns as potential
signals of underlying risks of an
operational, people-management, or
compliance nature.
The secondary interview data supports this
argument. Those managers who saw their
internal whistle-blowing arrangement as
just an additional procedure often
complained that employees were not using
the procedure for what it was meant:
employees were raising grievances rather
than concerns about harm to the public
interest. This corresponded with their
distrust of the whistle-blowing
arrangement as a whole. This contrasted
with other managers, who saw the
potential benet of whistle-blowing to the
organisation as an arrangement that
allowed a wider range of concerns to be
raised. They did not see employee
‘hacking’ of the procedure as problematic,
but were willing to spend additional effort
and resources to look into concerns that
did not include obvious ‘smoking gun’
evidence of wrongdoing.
4.2.2 Rule-bound referrals
Organisational policies that contained
rule-bound referrals9 of employee speak-
up concerns also inuence how speak-up
operators perceived their independence.
These restrict the discretion of both
managers and speak-up operators for
referring employee concerns for
investigation. Speak-up operators asserted
that these rules supported them in
investigating concerns that could lead to
sanctions against managers.
They also gave examples where these
rule-bound referrals mandated them to
take action where local managers wanted
to ‘wait and see’ how things developed, or
wanted to handle the concern themselves.
Some organisations had worked out
ow-charts for rule-bound referrals.
14Effective speak-up arrangements
for whistle-blowers
4. Trust as a process
Speak-up operators
argued that their level
of independence from
day-to-day operational
matters gave them
status as trustworthy
professionals.
9 The term ‘rule-bound referrals’ here means protocols and policies that specify rules for managers at different levels about how, when, and to whom within the organisation
a concern raised by an employee must be escalated.

‘If I look into the cases that
arise in the organisation, [some]
colleagues do not like it if I
give them to the compliance
organisation. So they say “we
should deal with it on our own,
and it’s not such a difficult case,
and it’s not so serious” and so
on…It’s easy for me because my
managers give me backing…
and I can say “if we don’t give it
to them, and the case escalates,
then we are part of the problem.
Please be part of the solution and
not part of the problem”.’
(Engineering company interviewee C)
‘Another obstacle may also lie
in the inspector himself. I have
worked for three inspectors
here. Two of them were good.
They were brave. If there was
something problematic, during
their years of service, they directly
confronted it with the head of
audit or, at least, with our prime
secretary. But the third inspector
did not have it at all…He said “Let
us wait, let us just wait for longer
time”. Although our leaders
already gave us freedom and [the]
necessary mandate to handle the
case but our boss just waited.’
(Central government interviewee F)
4.2.3 External independent advice
As noted in section 3.1, external
independent advice operators are
fundamentally distinct from externally
operated hotlines or external
ombudspersons. External independent
advice operators maintain a legal privilege
with the voicing employee and offer advice
in the interest of the whistle-blower. When
internal voice is ineffective or leads to
retaliation, these advisers will guide voicing
employees to the appropriate regulator, as
well as inform them about their rights under
the whistle-blower protection legislation.
Two of the four organisations studied
promoted an external advice line as part of
their speak-up arrangement.
‘When I first took over this job,
I thought they were a place
where people could actually
report. But their service is not
that. They never take reports
from individuals and escalate
them to us. What they position
themselves as is an advisory line.
So if I think there is something
wrong and I ring them and I
say, “I think this kind of thing
has happened and what do I do
and how do I go about it and
whatever?” Their role there is
talk me through the process, to
talk to me about the potential
impacts on me, what I might
have to go through in terms of
investigation, etc. and then to
leave me to make a decision with
regard to whether I will proceed
with that or not. And therefore,
all we get from them is numbers
[about how many people called
them for advice and the type of
concerns]… [Nonetheless this is
a] (v)ery high added value for us.’
(Bank interviewee H)
Contrary to what one might expect,
speak-up operators from these
organisations did not see the presence of
an independent advice line for employees
as opposing their own role. In fact, they
perceived that by facilitating employees to
seek their own advice, the speak-up
arrangement was made more trustworthy
even when that opportunity was not
actually used.
15Effective speak-up arrangements
for whistle-blowers
4. Trust as a process
External independent
advice operators
maintain a legal privilege
with the voicing
employee and offer
advice in the interest of
the whistle-blower.

16
The research demonstrates the importance
of having a robust and consistent response
system in place. Responding to concerns
raised not only demonstrates the
effectiveness of the procedure but also,
and as a result, contributes to developing
trust in the arrangement.
Conversely, a lack of responsiveness can
create the perception that speaking up is
futile and risky. Gradually a climate of
silence is formed through an interactive
process of collective sense making10 in
which salient events are exaggerated and
generalised (Morrison and Milliken 2000).
5.1 RECORDING SPEAK-UP EVENTS
‘Informal voice’ is dened as ideas or
concerns expressed directly and outside a
structured process (Klaas et al. 2012).
‘Formal voice’ is where the idea or concern
is recorded according to specic processes
and a systematic evaluation of the voiced
idea or concern is applied.
In the organisations researched, the
development of speak-up arrangements
always implied a formalisation of voice in
two ways: voice is increasingly recorded
and response to voice is increasingly
prescribed to managers at all levels.
Nonetheless, some interviewees reported
that they knew many organisations where
management still focused on encouraging
people to speak-up rather than paying
attention to how the organisation
responded to their concerns.
The additional provision of voice channels,
ie internal key persons, question channels,
and internal or external hotlines, provides
further opportunities to record voice.
Table 5.1 gives an overview of where voice
data is centralised in the four organisations.
In practice, the organisations differed in
the extent to which they recorded speak-
up voice. Some of them were still
deliberating on what exactly to record as
a ‘speak-up’. The engineering company
had the most developed policy on
recording voice, which corresponds with
the fact that it has the longest track history
of operating the speak-up arrangement
among those interviewed.
In the NHS Trust, concerns formally raised
under the speak-up policy were recorded
as speak-up events. Concerns voiced to
local managers would not be recorded, but
concerns voiced verbally with or written to
internal key persons would be. Anything
voiced, – concerns and questions –
through the internal hotline was also
recorded. The Director of Corporate Affairs
maintained the register and reported every
six months to the Audit Committee. The
external independent advice line provided
management with aggregated numbers of
concerns but did not allow management to
record the individual concerns raised with
them. It was possible, however, that an
employee would voice a concern with a key
internal person or through the internal
hotline after seeking independent advice.
The bank required its key internal persons
to advise voicing employees on whether
their concern would best be treated as a
grievance or as a speak-up. They were
required to record speak-up voice formally,
after which the Group Strategic HR took
over as the contact for the voicing
employee, and coordinated the
investigation. An employee writing a letter
to the CEO to voice a concern would not,
5. Responsiveness
Responding to concerns raised
contributes to developing trust
in the arrangement; conversely,
a lack of responsiveness can
create the perception that
speaking up is futile and risky.
10 Collective sense making is a process of story-telling and other verbal interactions, through which people come to have a shared un-derstanding of a situation without
necessarily having experienced that situation.
Director of
Corporate Affairs
Group
Strategic HR
Central
Compliance
Internal
Audit
NHS Trust X X X X
Bank X X X
Engineering company X X X
Central government X X
Table 5.1: Centralisation of speak-up data in the four organisations

however, necessarily or automatically be
recorded or treated as a speak-up. The
interviewees indicated that a policy on
what to record as a speak-up was still in
development. The ownership of the
speak-up arrangement had changed hands
a short while previously from compliance to
HR, and the bank was in the process of
deciding who would be its ‘speak-up
champion’ in response to the regulatory
requirement of the Financial Conduct
Authority (FCA).
Some were considering a more integrated
formalisation of voice:
‘the broad definition of speak-up
is somebody picking up a phone,
or sending an email through
a designated line or email
address…We’d have it through
other formats, but it’s not
actually categorised as speak-
up... So we’re actually missing a
trick in classification’
(Bank interviewee N)
The engineering company went furthest in
recording voice. Not only did it log
concerns voiced through the question
channel, but it also required local
compliance and HR managers to record
concerns containing a compliance aspect.
Central compliance monitored patterns
emerging from the integrated database.
The company produced manuals for
managers at all levels on how and when to
record voice. Interviewees reported that
the formalisation of recorded voice was
one of the key changes in the
organisation’s response.
In the central government, the speak-up
arrangement did not replace the role of
managers or HR director, within the
different agencies, in listening and
responding to employees but employees
could use the speak-up arrangement to
circumvent their hierarchical line when they
believed their supervisor to be involved in
the wrongdoing. Hence, concerns voiced
by employees only within their
departments would not be recorded.
5.2 LIAISING FUNCTIONS AND
DIVISION OF LABOUR
The responsiveness of organisations can
increase when two or more functions are
involved in operating speak-up
arrangements. Coordination between
different functions such as compliance and
HR, facilitated by clear protocols, allows a
division of labour in which each function
exercises its expertise.
At the bank, Group Strategic HR owned
the speak-up arrangement and liaised with
the Special Investigations Unit. One
function was to ‘mantle’, ie, to protect the
voicing employee and safeguard their
well-being, while the other function was to
investigate the potential wrongdoing:
‘…when a report [from a whistle-
blowing employee] comes in,
[the Special Investigation Unit]
is always the first point of
contact we would make, and
they’re effectively the internal
professional investigators. We
have a very strong protocol
around protecting the individual
by checking their comfort
levels…So [we are] keeping a very
distinct split between the case
manager, who typically will…
be someone in HR, someone like
me…and the investigator. [We
have] very, very clear divisions of
responsibility.’
(Bank interviewee K)
In the engineering company, central
compliance owned the speak-up
arrangement though it did not deal with
everything. Some of the concerns voiced
through the speak-up channels were
HR-related rather than compliance issues.
Compliance referred the HR-related
concerns to a designated HR ofcer at
headquarters, who would investigate,
sometimes devolving concerns to regional
levels and following them up there. Where
what appeared to be an HR-related matter
turned out to have a compliance element,
compliance would liaise with the HR
function under a clear protocol.
17Effective speak-up arrangements
for whistle-blowers
5. Responsiveness
The responsiveness
of organisations can
increase when two
or more functions
coordinate in a way that
allows each function to
exercise its expertise.

5.3 MAKING RESPONDING THE NORM
A lack of responsiveness is mainly an
outcome of managers’ fear of negative
feedback and implicit beliefs they often
held, eg ‘management knows best’ and
‘unity is good and dissent is bad’.
Managers receiving voice may pay
‘lip-service’ or act as if threatened and
might try to avoid embarrassment or
suggestions of incompetence and
vulnerability (Morrison and Milliken 2000).
Those operating speak-up arrangements
seemed to be aware of these managerial
tendencies and made attempts to tackle
them. Merely formalising voice channels is
not enough; they need to be embedded in
such a way as to thwart managerial
tendencies to deny or neglect them. Some
organisations in this research did so by
reinforcing the message that responding to
voice is part of a manager’s job and
retaliating is a disciplinary and legal breach.
‘I’m not saying all managers are
bad eggs out there but I’m saying
that they need to be driving this
themselves, and not just [leave
it] to an HR function to issue
policies and procedures every so
often, once a year.…That needs
to be on the forefront of people’s
minds that this is an avenue to
go down.’
(Bank interviewee N)
The continuous reinforcement of this
message is important. A model of manager
responsiveness based on the theory of
planned behaviour posits that the way
managers will respond to employee
concerns is inuenced by their personal
beliefs about whistle-blowing, social norm
cues the manager receives about
responding, and the manager’s perceived
behavioural control for responding
(Vandekerckhove et al. 2014a).11 The
rule-bound referrals discussed in section
4.2.2 can inuence manager’s perceived
behavioural control. Having speak-up
operators can also signal the norm about
responding to employee concerns.
‘But there’s no doubt about it:
you have to do it as part of the
overall agenda where we’re
saying to line managers, “It is
your responsibility to listen”,
and sometimes line managers
keep saying, “Well, I have my
own job to do”, and we have
to keep saying, “No, you’re the
people manager and part of your
responsibility is to listen, to act
and to respond”.’
(Bank interviewee H)
5.4 BARRIERS TO RESPONSIVENESS
From an employee perspective one of the
key attributes of effective voice systems is
credibility, and employees perceive a
manager to be fair when he or she provides
accounts and explanations for decisions
(Harlos 2001, Morrison and Milliken 2000). In
the context of concerns about wrongdoing,
giving account and explanation is not
always straightforward for management for
three reasons: anonymity concerns, legal
limitations, and the invisibility of response.
5.4.1 Anonymity concerns
Communicating back to someone who
voiced a concern anonymously is difcult, if
not impossible. Even when a manager
considers that the organisation is
responding to the voice, it is not always
possible to see it from the employee’s
point of view. A voicing employee might
be mistaken about their concern and
management may not take any action: in
which case the employee will perceive only
the lack of any management intervention.
‘[A]n individual invoked the
right to raise [something] on
an anonymous basis. They sent
it in in a paper format and we
investigated it. They have sent
that speak-up in three times now,
but because they’ve remained
anonymous, we can’t go back to
them to tell them we’ve looked at
it seriously, we’ve investigated it,
[but] we haven’t been able to back
up the claims. We don’t have any
more additional information.’
(Bank interviewee H)
18Effective speak-up arrangements
for whistle-blowers
5. Responsiveness
Merely formalising
voice channels is not
enough; they need to
be embedded in such a
way as to reinforce the
message that responding
to voice is part of a
manager’s job.
11 The term ‘perceived behaviour control’ refers to someone’s perception of the ease or difculty of performing a specic behaviour. Thus, managers might personally
believe it is good that employees voice a concern, and they might also receive cues from higher man-agement that it is important to respond to these concerns, but if
these managers do not know how to respond or do not believe they are adequately mandated to respond, they might still neglect the concern. This model of managerial
responsiveness builds on Ajzen (1991).

‘Perhaps the information that
we act [on] and [how we] handle
the whistle-blowing cases is not
spread out to the employees.
As far as I know, when I, the
CEO or his deputies receive an
anonymous letter, we do respond
and act upon it.’
(Central government interviewee A)
Before the review of their speak-up
arrangement, the NHS Trust received an
anonymous concern and had escalated it
to the board level. The investigation had
not been conducted fast enough for the
voicing employee, who thought that the
concern had been ignored. The employee
blew the whistle to the regulator, who
authorised an inspection.
Anonymous speak-up often occurs through
a purposely made email account, eg
whistle333@hotmail.com. The speak-up
operator would be able to communicate
further with the employee who has created
the account, but a problem arises when the
employee fails to check it after that, thus
making it a de facto one-way anonymous
communication. This can be an additional
challenge to responsiveness because it is
not possible to ask for additional
information about the alleged wrongdoing.
5.4.2 Legal issues
Speak-up operators along with other
interviewees reported that communicating
the outcome of an investigation is
necessarily limited on legal grounds.
Conveying details can inhibit legal
proceedings against a wrongdoer.
Privacy and data protection regulation
also limit what can be communicated
about an investigation or outcome.
Hence, communications about
investigations and outcomes are nearly
always vague. This may create the
impression with the voicing employee that
their concern is not taken seriously. It is
therefore necessary that speak-up
operators manage the expectations of
voicing employees, by giving them an
indicative timescale as well as informing
them of regulatory limitations that may
limit the detail given in the response.
5.4.3 Invisibility of the response
Even when sanctions are taken against a
wrongdoer these are not always visible; for
example, a minor wrongdoing might be
punished by a reprimand or a formal
warning. Nevertheless, it is the perceived
as well as the real response that matters for
individual and collective sense-making
about management’s responsiveness. This
can affect the perception of how effective
(or futile) it is to raise a concern.
5.5 FACILITATORS OF RESPONSIVENESS
Although management’s ability to
demonstrate responsiveness may be
limited for the reasons mentioned above,
some actions against wrongdoers are
visible. Some of the organisations studied
seemed to assume there were enough of
these visible cases to create a shared
perception that the organisation was
responsive to speak-up concerns. Speak-
up operators in the central government
assumed that employees are able to
recognise organisational responsiveness
even from less visible sanctions.
‘We received a whistle-blowing
letter and then the wrongdoer,
who was a middle manager, got
sanctioned. We transferred him to
another office and demoted him.
Everybody knows why. We did
respond to the whistle-blowing
information but we do not need to
announce that he was punished
because of the case. Smart
employees will be able to see that
the whistle-blowing information
was acted upon. The wrongdoer
has been caught, and that’s it’
(Central government interviewee A)
At the engineering company, word-of-
mouth communication of visible responses
among staff was relied on to create a
shared perception of responsiveness.
‘From time to time, if somebody
does the wrong thing, he or she
has to leave the company, and
everybody knows it…they hear it
[through the] grapevine, that this
or that person had to leave the
company because of bad behaviour.’
(Engineering company interviewee D)
‘[It’s] quite easy for every single
employee from the company in
this country to understand that
the rules apply to everyone and
the system works. It’s not a thing
that I need to emphasise very
much here’
(Engineering company interviewee E)
19Effective speak-up arrangements
for whistle-blowers
5. Responsiveness
Privacy, anonymity
and data protection
regulation may limit
what organisations can
communicate.

Management may need to nd ways of
creating better perceptions of
responsiveness. The NHS Trust, for
example, used the intranet to publish
answers to voiced questions or concerns
where no other person is accused of
wrongdoing.12 Such as system makes the
response process visible to all staff rather
than relying on word-of-mouth among
employees or hoping that some cases are
sufcient on their own. In this way, the
NHS Trust tried to maximise the
opportunities to form a shared perception
of effective organisational responsiveness.
Research literature notes that a supportive
organisational climate is needed for
whistle-blowing or voicing concerns about
wrongdoing. Nonetheless, the literature
remains vague as to the factors that create
such a climate (Miceli and Near 1992). The
present research suggests that because
organisations have only limited agency in
being responsive to employee voice, it is
important for management to be as
responsive as possible even where a
speak-up channel is used to voice concerns
that do not lead to investigations or
sanctions. Without a proper speak-up
arrangement, these concerns would be
neglected. Organisations may, on the
contrary, see these concerns as an
excellent opportunity to demonstrate their
responsiveness, as they are not bound by
legal limitations and can thus communicate
the response internally.
The NHS Trust also had positive
experiences with involving an employee
who had raised a concern, in developing a
solution to the problem. It must be noted
that the concern in question related to an
operational matter rather than a
compliance-related issue. The employee
who had spoken up was made part of the
team that subsequently developed and
implemented a solution to the problem.
This had generated positive collective
sense making. Arguably, organisations
should not underestimate the importance
of such events for effective speak-up
arrangements. In the secondary interview
data there were instances where
unresolved operational concerns had
grown further into problems harming
clients and the public interest, and had
made whistle-blowers escalate their
concerns to regulators and the press.
20Effective speak-up arrangements
for whistle-blowers
5. Responsiveness
Organisations must
find ways of creating
better perceptions of
responsiveness by
making responses
visible where possible.
12 An example is a nurse who was concerned that the radio was playing music during operations and asked whether this might constitute a risk to patient safety

Speak-up arrangements integrate voice
channels by centrally recording and
tracking employee concerns. This enables
top management and board members to
measure ‘voice climates’13 at various
locations and levels within the
organisation. Organisations in the sample
were at various stages in making use of this
additional data.
6.1 PATTERN RECOGNITION
Consistently across the cases, top
management intended to use data from
the speak-up arrangement to steer
management responses to voice at
different levels. At the time of the
interviews, most of the organisations
reported aggregated numbers to the
board and outcomes of investigations into
alleged wrongdoing to top management.
‘We simply report on facts.
The more we report on these,
it’s down for management to
learn based on the work that we
do. It’s down to management
at the senior level to say, “Look,
enough’s enough”, and then
send that message down, and
then reiterate about the speak-
up policy.’
(Bank interviewee N)
The engineering company and the NHS
Trust were performing pattern recognition
of all speak-up data to spot potential
issues underlying unsubstantiated
concerns. The engineering company went
further by communicating and following up
potential issues identied from the pattern
recognition. The rm argued that a
systematic follow-up of all concerns voiced
through the speak-up channels had helped
it to strengthen its risk management. In this
sense speak-up arrangements not only
help organisations to deal with issues
before they blow up, but also improve the
risk awareness and internal controls of a
proactive organisation.
The other organisations were still
discussing whether a concern voiced
informally at local level should be recorded
as a ‘speak-up’ at all.
6.2 DATA FOR TRAINING PURPOSES
The organisations in this research were
reluctant to use speak-up data for training
purposes. The interviewees mentioned
condentiality and keeping the whistle-
blower safe as the main reasons for this.
‘We have not ‘cultivated’ the
attitude of giving reward to the
whistle-blower explicitly in
front of other employees. Do
you know why? If we give them
reward and we announce that
they are the whistle-blowers,
they will die again [from being
the centre of attention.’
(Central government interviewee A)
‘I can’t work out a way to do it
without the individuals who
raise issues feeling a little bit
compromised.’
(Bank interviewee H)
Although the speak-up operators in the
engineering company sometimes used
speak-up cases for training purposes, they
preferred focusing on the ‘back-ofce’
process of what happens with an employee
concern, emphasising the independence
of investigation and follow-up.
6.3 PUBLISHING AGGREGATED SPEAK-
UP DATA
Another way in which the speak-up data
could be used is by making aggregated
numbers from the speak-up arrangement
publicly available. Two of the organisations
in the research had recently signed up to
the ‘First100’ campaign launched in the UK
by Public Concern at Work,14 which
commits them to publishing speak-up
numbers in their annual report. At the time
of writing, these organisations had yet to
have the experience of doing so.
Public Concern at Work conducted research
on initial experiences of the First100
signatories (Public Concern at Work 2015).
One of the respondents said that they had
received questions from investors about the
types of concern that employees had raised
through the speak-up arrangement. While
management found this a positive interest
6. Using speak-up data 21
Speak-up data can help
organisations strengthen
their risk management by
improving their risk awareness
and internal controls.
13 The term ‘voice climate’ refers to the set of shared beliefs about how safe and effective it is to voice a concern.
14 When organisations sign up, they pledge to implement a speak-up arrangement in line with the Code of Practice published by the Whistle-blowing Commission. For
more info on the First100 campaign, see http://www.pcaw.org.uk/law-policy/the-rst-100 (accessed March 2016). For more info on the 2013 Whistle-blowing Commission
and its report, see http://www.pcaw.org.uk/law-policy/whistle-blowing-commission (accessed March 2016).

from investors, it nevertheless remained
‘nervous’ about reporting numbers publicly,
as it might trigger an inux of questions
from other stakeholders.
Although not a signatory to the First100
campaign, one of the organisations
studied published aggregated numbers
from its speak-up arrangement in its annual
report. A speak-up operator from that
organisation claimed that sometimes the
gures are misinterpreted: ‘Sometimes we
receive questions from journalists who
want to have more detailed numbers [but]
you cannot compare the incoming cases of
one period – one year or one quarter –
with the disciplinary measures and the
closing of the cases, because sometimes
complex investigations take more than half
a year or more than one year in total.
‘Therefore, the numbers do
mostly not refer to the same
cases, they are just stating
the in[put] and output of
cases without saying anything
about how much is still on-
going within the compliance
organisation. If we in one year
have an incoming number of
100 cases and in parallel to that
outline disciplinary measures in
or closing of 60 cases, that does
not mean we are only handling
60 of the 100 cases. We may
very well have 40 open cases
which are passing on to the next
quarter or the next year.’
(Engineering company interviewee B)
This interviewee nevertheless also saw the
benets of reporting numbers publicly:
‘I think, from that intense culture
of internal transparency but
as well of pride concerning the
effective first steps already taken,
the motivation arose to put certain
figures in the annual report’
(Engineering company interviewee B)
As more organisations publish data from
their speak-up arrangements, a voluntary
standard of what numbers to report and
how to report them could reduce the risks
that information will be misunderstood and
that other issues will arise from increased
transparency. Such a standard might also
be helpful for the further development of
best practices in designing and
implementing speak-up arrangements.
22Effective speak-up arrangements
for whistle-blowers
6. Using speak-up data
As more organisations
publish data from their
speak-up arrangements,
a voluntary standard of
what and how to report
could evolve, helping
the development of
best practices.

To be effective, speak-up arrangements
need to take into account the interactions
between cultures and specic speak-up
systems. Three types of cultural
differences, national, organisational and
language-based, are reviewed below.
7.1 NATIONAL CULTURES
There is no agreement in the research
literature about the extent to which
whistle-blowing practice is determined by
national cultures.15 In countries where
corruption and bribery are said to be more
widespread, or sometimes even assumed
to be ‘part of the culture’, people have
nonetheless spoken up and stood up to
corruption by means of hunger strikes and
mass street protest (Financial Transparency
Coalition 2011).
The interview data from the present
research, collated from interviewees on ve
continents, suggests that having concerns
about possible wrongdoing and
attempting to voice these concerns is
universal. Nevertheless, depending on the
geographical location, it emerged that
employees may prefer different channels
for voicing their concerns.
Speak-up operators in the engineering
multinational found that in some parts of
the world people preferred to speak
directly to a compliance ofcer rather than
calling a hotline or voicing their concern in
written form through a Web application.
The external ombudsperson was
sometimes used to raise a concern in
Central Europe, the Middle East and Asian
countries, but much less by employees in
Northwest Europe, North America or Latin
America. These differences were relative,
however, rather than absolute. Hence it
appears that other factors, beyond merely
national culture, also play a role.
Although they are able to overcome
national cultural tendencies to some
extent, organisations nevertheless remain
open systems. Issues arising within society
can trigger an increase in the number of
employees voicing various concerns
through the speak-up arrangement.
Examples from the interview data include
concerns of employees in Latin America
voiced within the organisation but
triggered by media reports of corruption
cases in the region unconnected to the
organisation. Another example involves
employees who voiced concerns about
colleagues who had written posts on their
private Facebook pages that were
unsympathetic to migrants, triggered by
the discussions about the refugee crisis in
Europe. The organisation that dealt with
this was only able to do so because the
‘back ofce’ of the speak-up arrangement
was appropriately resourced so that
speak-up operators had the time and
expertise to understand that not
responding to these concerns would in
itself pose a risk to the organisation.
7.2 ORGANISATIONAL CULTURES
As we discuss below, organisational culture
can overcome national cultural differences
Organisations should therefore take into
account the potentially difcult interactions
between organisational and national
cultures when developing and
implementing a speak-up policy.
Speak-up operators from the central
government organisation said that one of
the difculties of implementing the
speak-up arrangement was perception:
people see it as an imported concept that
cannot be directly implemented without
considering the local context. One
interviewee suggested this was not specic
to speaking-up but could also apply to
other processes.
‘Which one is wrong? The
concept or the culture? Or did
we not culturally prepare to
implement the whistle-blowing
system?…Another example,
the commuter rail company
brought in a new concept from
outside that passengers should
use a train card instead of cash.
The people were not ready.
The automatic ticket checking
machines were vandalised and
passengers jumped up over
the machine…To implement a
good concept, everything should
be prepared. The preparation
includes developing awareness
and desire to change, providing
insight and understanding as
well as knowledge. So far, it is
only skin deep.’
(Central government interviewee A)
7. Interactions with culture 23
The interactions between
cultures can impact the
effectiveness of speak-up
arrangements.
15 For a review of the research and an overviews of the debate, see Vandekerckhove et al. (2014b).

The engineering multinational uses a
global expat strategy to ensure consistency
across regions. Regional speak-up leaders
either came directly from the country
where the head ofce is based or had
spent a number of years there so they were
familiar with the speak-up policy and were
well placed to help replicate it accordingly
in other locations. The company was
determined to keep this practice, and
maintained that the use of speak-up
channels in a particular region always
increased directly after a visit from the
head ofce to talk about compliance
issues. This does not mean that
overcoming regional differences happens
easily. One interviewee from Latin America
explained that, when rolling out the
speak-up arrangement, the head ofce
clearly explained what structures,
mandates, and reporting lines had to be
implemented. Even so, it had taken a while
for managers in the region to grasp the
rationale and the intended cultural
changes behind this.
7.3 LANGUAGE
Coping with language differences is
another factor that determines the
effectiveness of a speak-up arrangement.
The engineering company made its
Web-based and hotline speak-up channels
available in all the languages where it
operates. An interviewee from Latin
America nonetheless believed that
employees use those channels because
they assumed that the external
ombudsperson would not be able to
understand Spanish or Portuguese.
Another successful example from the rm’s
compliance ofcers who oversaw certain
parts of North Africa suggests that having a
shared conversational language, in this
case French, made it comfortable for
employees in the Maghreb and West
Central African countries to voice a concern
directly to compliance ofcers. These
examples show the importance of having
multiple channels with different interfaces.
24Effective speak-up arrangements
for whistle-blowers
7. Interactions with culture
Multi-national
organisations must
consider the languages
spoken where they
operate and what it
means for the speak-up
channels.

This research project examined the
opportunities, challenges and best
practices associated with different types
of speak-up arrangements, on the basis
of four case studies. The speaking-up
arrangements were examined from the
viewpoint of those who develop, operate
and oversee them.
The four organisations in the study
provided various combinations of voice
channels. These channels consisted of two
broad categories: internal and external.
Internal channels are more direct but face
the challenge of independence. External
channels can vary from outsourcing of the
hotline function to external independent
advisers, depending on their distance from
the commissioning organisation. The use
of digital technology may help circumvent
some of independence issues but it is too
early to measure its implications.
It is often considered that trust is important
for effective and safe whistle-blowing. This
study shows that the development and
operation of the whistle-blowing
arrangement can themselves help to
cultivate trust. Trust building is a
continuous process that may interact with
speaking-up practices over time. For
example, the successful operation of
external whistle-blowing channels can
encourage employees to start trusting
internal channels. The key element in this
process appears to be the independence
of the channel.
Responsiveness to concerns raised crucially
affects the perceived and real effectiveness
of whistle-blowing arrangements. Various
factors affect responsiveness, including the
recording of speak-up events, coordination
of follow-up activities, and management
attitude towards whistle-blowing practice.
There are furthermore barriers to
responsiveness caused by the anonymity of
voices, legal issues, and the invisibility of
the response.
Recorded speak-up and whistle-blowing
data can help management and the board
assess the effectiveness of their whistle-
blowing arrangements. Analysis of the
pattern of concerns voiced by employees
can help an organisation recognise risks that
have previously been unidentied. Externally
published speak-up data can facilitate
better collective understanding of whistle-
blowing arrangements that work in practice.
To enable an effective whistle-blowing
arrangement, organisations need to
consider how the arrangement interacts
with cultural issues. While cultural
challenges are surmountable, this might
take time and effort. Organisations may
also need to consider suitable strategies to
address issues such as regional differences
and language.
8. Conclusions 25
Developing and operating
effective speak-up
arrangements help cultivate
trust and functional behaviours
in organisations.

RECOMMENDATION 1:
Provide a variety of voicing channels and consider the use of
an external independent advice channel when introducing a
speak-up arrangement.
Speak-up arrangements often consist of different voice channels.
The use of these channels can change over time, reecting the
development of trust in the arrangements. Each of these channels
comes with its own barriers, eg independence, anonymity and
perceived accessibility, inuenced by national culture, language
and societal context. Hence providing employees with a range of
channels through which to voice their concerns increases
accessibility, as characteristics of one type of channel compensate
for the barriers imposed by another. The use of an external
independent advice channel where employees raising a concern
can seek advice under legal privilege can also help.
RECOMMENDATION 2:
Be prepared to accept that concerns received may not be
strictly considered speak-up or whistle-blowing cases.
While some concerns may initially appear to be individual
grievances or even trivial, they may nonetheless help
organisations recognise previously unidentied risks.
RECOMMENDATION 3:
Design a speak-up ‘back ofce’ to record concerns and use
this data to strengthen risk management and response
processes, investigation and intervention, acknowledging the
variety of concerns that could be raised.
To be effective, speak-up arrangements specialist staff in different
functions (compliance, HR, audit) liaise with each other to follow
up different types of concern, with a clear division of labour. The
collated data can help management develop better risk
management as well as to understand the effectiveness of the
whistle-blowing arrangements.
Concerns raised through the different speak-up channels can be
recorded and centralised. Best practices involve systematically
recording voices and using this data for pattern recognition.
Differences between departments or regions in the types of
concern raised, as well as differences as to which speak-up
channels are most used, allow speak-up operators to have an
understanding of the different voice climates in the organisation
and therefore enhance the effectiveness of the arrangements.
RECOMMENDATION 4:
Responsiveness needs to be well organised, clearly mandated,
and adequately resourced.
Merely encouraging employees to speak up, without putting
robust response systems in place, will have negative
consequences, both for employees and for the organisation.
Effective speak-up arrangements come about by designing and
organising effective response to concerns raised. The complexity
of the information ows should not be underestimated. Speak-up
operators can only make the organisation responsive when they
work with a clear mandate and are adequately resourced. Getting
the response right is the rst and most effective step towards
encouraging employees to speak up.
RECOMMENDATION 5:
Make responses visible where possible.
This may be achieved by exploring whether employees who
raised a concern can be included in developing a solution to the
problem. This in turn can contribute to developing collective
sense-making and increase trust in the effectiveness of the
speak-up arrangement. It is also important to emphasise
continuously, to managers at all levels, that responding to
concerns is part of their role and to restrict their discretion about
whether/how to respond.
Organisations may also nd it challenging to decide how and
what they can communicate about the outcomes of investigations.
These limitations can be related to concerns voiced anonymously,
legal issues about information that can be shared, and often also
to the invisibility of sanctions imposed. Some organisations relied
on word-of-mouth among employees, while others try creating an
organisation-wide awareness by openly discussing a case story
that does not involve individuals being named. In some cases,
organisations can also seek to engage with the voicing employee
in resolving the problem identied.
RECOMMENDATION 6:
Consider participating in the development of a standard for
the public reporting of data from speak-up arrangements.
Speak-up operators are sometimes uncertain about reporting
publicly aggregated numbers from their speak-up arrangement.
While increased transparency can be a potential source of
credibility for various stakeholders, there is also fear of rst-mover
disadvantage in the sense that the information might be misread.
This can be overcome if more organisations start sharing
information in the public domain in the future.
9. Recommendations 26

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References 27

EA-WHISTLE-BLOWING
www.accaglobal.com/whistleblowing
ACCA The Adelphi 1/11 John Adam Street London WC2N 6AU United Kingdom / +44 (0)20 7059 5000 / www.accaglobal.com