With this inaugural post on the Evince blog I thought I would offer some thoughts regarding considerations that corporations and government departments should address when researching third-party ethics complaint companies (a.k.a. hotline companies).

As far as opening post go, this is not exactly fireworks and a ribbon cutting ceremony, but this is definitely a topic of interest for companies looking to bolster their ethics program.

This four point list is by no means exhaustive, but it’s a good starting point. Furthermore, based on the experience of our professionals these points make a big difference when it comes to encouraging the use of, and enforcing an ethics program.

1. What interface options does the company offer? Not every complainant will communicate the same way, so it is important to consider what options are available to complainants for making their submission.

Some complainants will prefer an anonymous web interface, others will wish to call a 1-800 number to speak with an actual person. There will be a third group who will prefer an email contact point and a fourth group that want a postal address so they can send in their complaint that way. The more options available to complainants, the more likely they will find one that they are comfortable using, which of course means more information for the Compliance Officers will have to be able to do their job.

2. How skilled are the interviewers at the hotline company and how detailed is the questionnaire on the web reporting tool? If the complaint receiving company provides a call centre service you should try to determine the level of training and experience the interviewers have. An experienced interviewer can go a long way towards obtaining useful information and conversely an untrained interviewer can thwart the effort all together. You will also want to find out if the company has the language capabilities that are required by your workforce. Finally, ask for redacted samples of their reports so that you can get an understanding of the information obtained and the quality of the writing.

Similarly, if the complaint mechanism is a web-interface, are the questions specific to your company’s culture or are they too general? Is the tool user-friendly? Does it allow for both open ended and closed ended questions?

These may sound like basic considerations, but they will really impact the quality of the information received in the complaints. Furthermore, even though it is an outsourced company you’re looking at, your employees, vendors and partners will look at this company as an extension of your firm and therefore your reputation will be affected by the representations made by the hotline company.

3. Where is the data stored? An organization must seriously consider where the archived complaints are stored. Is it in a jurisdiction outside your own? If that is the case, it is then subject to that jurisdiction’s laws i.e. think of a company from Canada using a third party hotline company based in the United States. That Canadian company’s stored complaint’s are now subject to the Patriot Act.

4. What other features are available? A complaint reporting service is only useful if your employees or constituents are aware of its existence. Furthermore, they also need to know what constitutes a violation of the department’s ethics policy. Some business conduct hotlines will provide educational videos and other resources which your organization can leverage in order to get the message out, while saving cost and effort.

Whether your organization falls under the jurisdiction of Sarbanes-Oxley, the Public Servants Disclosure Protection Act or you’re just interested in implementing best practices in your compliance program, you will want to ensure that at a minimum, these basic requirements are met when selecting an ethics and compliance hotline company.