If you have a whistleblower hotline—or a compliance program in general—employee awareness and training are likely not new concepts to you. However, the EU Whistleblower Protection Directive extends the scope of required awareness and training to all protected whistleblowers… and that includes contractors, vendors, and other third parties. With the Directive deadline of December 17, 2021 looming, it’s worth reexamining your hotline awareness strategy and coming up with something that is effective, practical, and in line with Directive requirements.
But first—if you’d like to know more about the EU Whistleblower Protection Directive in general, start with one of our previous blog posts in this series:
- The EU Whistleblower Directive Part 1: Everything You Need to Know
- The EU Whistleblower Directive Part 2: How to Comply With The EU Whistleblower Protection Directive
- 1. The EU Whistleblower Protection Directive: The Vital Few Actions You Must Take
- 2. The EU Whistleblower Protection Directive: Finding a Hotline Vendor That Will Help You Comply
- 3. The EU Whistleblowing Protection Directive: Hotline Reporting Requirements
- 4. The EU Whistleblower Protection Directive: Consequences and Practicalities
- 5. The EU Whistleblower Protection Directive: Retaliation and the Reverse Burden of Proof
EU Whistleblower Protection Directive Requirements for Hotline Awareness
The Directive asks companies to take into account a wider population than their employee base when it comes to whistleblower hotline awareness.
We’ve written several resources on raising whistleblower hotline awareness and generating engagement with your compliance program—and those principles apply here as well. However, the Directive asks companies to take into account a wider population than their employee base when it comes to hotline awareness. Therefore, it’s worth looking at typical whistleblower hotline awareness strategies through a new lens, one that includes vendors, contractors, interns, and more.
Standard whistleblower hotline awareness strategies include workplace posters, emails, and team briefings. Emails and meetings are easily expandable to your third-party work-based relationships. While workplace posters may be less visible to third parties, consider other materials that are passed back and forth through the course of business. Can you include a pamphlet on the hotline alongside your invoicing materials? Consider your ethics and compliance program’s online presence as well. If your Ethics and Compliance Portal is accessible outside the firewall, add a QR code for it to all your third-party communications, as well as employee materials like pass cards, pay slips, and more.
When strategizing your hotline awareness communications, it’s imperative to see things from the perspective of a potential whistleblower.
When strategizing your whistleblower hotline awareness communications, it’s imperative to see things from the perspective of a potential whistleblower. Address the key questions that will arise, like “Who will know about my report?” and “What will happen after I submit a report?” Proactively provide answers that can help address reluctance, and your awareness campaigns will be more effective.
Finally, one of the major barriers to whistleblower reporting is fear of the unknown. Consider a few measures to address it:
- Try branding your whistleblower hotline or giving it an identity. Convercent customers have had success with brands like “Talk to Peggy” or “Ask Veronica.” This humanizes the hotline and reduces the perception that reports are submitted to a nameless agency.
- Use reassuring imagery (one Convercent customer used posters of dogs) in awareness campaigns to make the hotline recognizable while subliminally reassuring viewers.
- Run a simple competition that invites employees and those with work-based relationships to submit a test report. Everyone who participates is entered in a raffle. Through submitting a test report, each potential whistleblower gains practice and becomes familiar with the reporting process.
- Define the terminology associated with whistleblowing, like “anonymous” and “confidential.”
Training Employees on the EU Whistleblower Protection Directive
The Directive includes a requirement that employees and third parties are made aware of the Directive and the protections that whistleblowers are entitled to under it.
The EU Whistleblower Protection Directive includes a requirement that employees and third parties are made aware of the Directive and the protections that whistleblowers are entitled to under it. That training must cover the three-tier reporting provision—where reporters are protected whether they report internally to the company, externally to a regulator or other recognized institution, or externally to the media. This training can be folded into regular compliance training or stand on its own; either way, it must happen.
More detailed training on the Directive may be limited to managers, case handlers, and groups who interact more closely with ethics and compliance initiatives. This training may cover the extended requirements of the Directive, variations across Member States, and anti-retaliation strategies.
Master the other requirements of the EU Whistleblower Protection Directive with our free Masterclass series
Prepare to comply with the requirements of the EU Whistleblower Protection Directive by the deadline of December 17, 2021, with this free series of eight expert-led webinars.