Skip to content


Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Hotlines inhibit honest feedback, and other reasons people clam up

Compliance professionals often ask me how they can better communicate with their front-line teams. I usually respond, “Bring them in, ask them about the real risks they face, and the more upset you are by what you hear, the better that conversation is going.”

Why? Because you can only fix what you know.

That was the topic of an article in the latest edition of the Harvard Business Review, Can Your Employees Really Speak Freely?

The authors, James Detert and Ethan Burris, identify two main reasons why employees don’t speak up: fear of consequences, and a sense of futility.

What about anonymous hotlines? Here the authors explode the conventional wisdom. “Allowing employees to remain unidentified actually underscores the risks of speaking up-and reinforces people’s fears.” 

In other words, the message from an anonymous hotline is, “It’s not safe to share your views openly in this organization.”

As to the open doors in the C-suite we often read about, the authors found them “simply too passive.”

So how do we address “candor-inhibiting behavior” and getting beyond “pseudeoparticipation?” Here are a few recommendations from Detert and Burris about how to encourage those who face corruption risk to speak up:

Be specific: Bringing in your teams (or going to see them) and asking them to open up is unlikely to inspire dialog. Instead, “specify the kind of input you are seeking” and (my suggestion) share why — to help them manage corruption risk by calibrating compliance tools to the real-world risk they face.

Follow up: When the sessions are over, “synthesize the information and then take action.” Don’t add your meetings to the graveyard of rolling-eyes events where front-line teams feel their time was wasted on perfunctory summits with no result or follow-up. In other words, make sure you tell them what you are going to do next for follow-up, and what they can then expect as a result.

Cast a wide net: In addition to those in the field who have direct contact with corruption risk, consider others who might know something you don’t. Those employees could be deep down in your organization, working in credit and collections, sales order processing, and logistics. Processing an international order typically requires many hands, and you might be surprised what some members of your support teams see and hear.

Also, when onboarding new international team  employees, ask them how the same compliance process was done in their previous position. Sometimes new employees are anxious to share how other organizations operate and will have a fresh perspective on your firm’s strengths and weaknesses.

Soften up: “If you want to get the truth from below, play down your power when interacting with employees.” I once worked for someone who was an officer in the U.S. Military. He shared with me that after a training exercise, he would bring in the unit for a “best-of, worst-of” session. He would tell his team to come in civilian clothing, as he wanted no visible signs of rank or privilege. What he wanted was open and honest dialog, even about his own leadership. Think about the strength of that message.


As Detert and Burris conclude in their HBR article, “Most people care too much about their social and material well being to routinely speak truth to power.”

So to clear the obstacles to real communication about risk and compliance, help people feel safe and believe that their time is well spent, no matter where they (and you) sit on the org chart.


Richard Bistrong is a contributing editor of the FCPA Blog and CEO of Front-Line Anti-Bribery LLC. He was named one of Ethisphere’s 100 Most Influential in Business Ethics for 2015. He consults, writes and speaks about compliance issues. He can be contacted here.

Share this post



  1. The challenges of ‘honest and open feedback’ identified in the recent Harvard Business School article (‘Can your employees really speak freely?’) is quite commonplace in most, if not all, organisations. The authors rightly identify a host of reasons for employee reticence; yet we know that members of staff are in the best position to identify your organization’s strengths and vulnerabilities in order to avert a crisis and to implement lessons learned following a critical incident.

    As experienced facilitators, we have found that more often than not a few voices may ‘dominate’ discussions and that others remain silent for a whole host of reasons: hierarchical constraints, shyness of individuals, cultural reasons, confidence etc. As a result, the real learning is often not captured and leads to the development of processes, procedures and training programmes that may not truly reflect the need of the organisation!

    Unlike the authors, we have found real value in anonymisation. But with these differences: As independent debriefers with a method in which total anonymity can be demonstrated, we have never had an engagement result in a post-event ‘witch hunt’ amongst the client’s employees. Additionally, given our approach and the analysis that accompanies it, our experience has been that the ‘message’ provided by employer to employees is that, rather than there being a risk in speaking out, the business has taken a ‘leap of faith’ and wants to strip away the inhibitions and fears of consequence that members of staff might otherwise have. Interestingly, that experience has been the same across all sectors and in every jurisdiction in which we have worked.

    So what is our approach? The need for open and honest discussions is, unsurprisingly, our starting point. To achieve that, we built developed a specific ‘debriefing’ methodology that works through a system of inter-connected laptops/devices that permits anonymised input (Solve: Interactive – This is quite distinct from the use of anonymous hotlines, which, as the authors highlight, often carries real difficulties with it and, in some instances, produces decidedly unfavourable consequences.

  2. While efforts to bring employees in and encourage them to speak openly should be applauded, I think it’s very dangerous to start arguing that the presence of anonymous reporting mechanisms is somehow counter productive.

    Humans are social animals. We have very strong allegiances to the group and we suffer great pains at even the thought of going against it, even when we see wrongdoing.

    We are reminded of the risk constantly. Children who report wrongdoing are labeled as tattletales. Adults who are whistleblowers regularly report being ostracized by their peers, even if their employers treat them properly. And, who hasn’t been criticized for not keeping something in the family?

    The challenge is going to be there, whether there is a hotline or not, because it seems built into our nature.

    The hotline simply makes it easier for people to come forward with less risk.

    Saying we should eliminate them because “…the message from an anonymous hotline is, ‘It’s not safe to share your views openly in this organization’” is like saying we shouldn’t have air bags because they send a message that is it’s not safe to drive a car.

    Everyone knows there are risks to reporting incidents and driving. Hotlines, like air bags, lessen those risks., and very few of us would ever think of buying a car without airbags.

  3. Where in the real world is there an organization that has the culture and senior management that are the 2 preconditions for more disclosure without a hotline: First, a culture where disclosure of problems and misconduct are always welcomed and people raising issues are always rewarded and protected instead of punished, and Second, a senior management that holds leaders accountable at all levels and actively seeks to hear bad news as well as good news, even about popular and successful employees?

    The military of any country? Any religious organization that you can think of? Any political party or organization? Any bar association? Any medical association? Any companies you can think of where it is UNIVERSALLY the case as opposed to OCCASIONALLY the case that people who raise tough issues or questions are rewarded and protected?

    Sadly the real world is a place where bad news is rarely welcome and the loyalty of people who bring bad news is routinely doubted, and where leaders act on the desire for self-protection when a subordinate challenges them or has to go around them on issues of compliance.

    I don't doubt that many companies and many senior leadership teams are entirely sincere in their commitment to values and compliance. I spent a career in that kind of company and with that kind of senior leadership.

    But the leadership in an enterprise consists of multiple levels and at any one of those, it only takes one person who is involved in misconduct or doesn't believe in disclosure to poison the entire unit around him or her. One leader whose response to a problem is: "WHO TOLD YOU?" "HOW DID YOU FIND OUT" "WHO HAVE YOU TOLD" sends a message that is much more powerful than the existence of a hotline. One whistleblower who is punished sends a message that is much more powerful than the existence of a hotline.

    It is a huge challenge for leadership, because a single failure to act on an issue or protect a whistleblower sends such a powerful message through the enterprise about the consequences of being identified as the source of bad news. I believe the positive message of a hotline (if issues raised are acted upon) and its promise of anonymity is far stronger than the negative message.

  4. A few comments on this interesting exchange. First, the initial point, that employees don’t raise issues because of an expectation that nothing will happen, and fear of retaliation, is very old news. I think anyone who looks into the topic finds this. It was certainly a point made well by Miceli & Near in their 1992 book, “Blowing the Whistle.” Thus, we know we need to try to protect those who raise questions, and we need to show that we have responded and, as appropriate, taken action. This is one reason for publishing disciplinary cases (sanitized) – to show that something does get done in response to calls.

    Regarding the facially silly idea that having an anonymous calling system somehow causes people not to speak up, I can’t even imagine a rational basis for this. But the experience of many if not most of us who have done this work is that the best information typically walks in the door, calls us directly, or talks with us when we are out in the field – it does not come in through the helpline. As I have described it in my SCCE Compliance and Ethics Professional Magazine column, a helpline in effect, gives your employees a “permission slip” to speak up. Knowing they have that option seems to make them feel freer to raise questions directly. Also, importantly, having an anonymous reporting system communicates to potentially abusive bosses that their employees do have a way to get help.

    I am not sure it takes a team of outside experts or Harvard articles to do this work well. But it does take a deep understanding of what the word “listen” means. I have read that for most people, listening means thinking of what they will say next as soon as the other person stops talking. But when a nervous employee wants to ask you a question, or discuss a “what if” issue, you need to be 100% focused on that person and making him or her feel comfortable in talking with you.

    If you want to listen to your employees, go where they are and talk with them on their terms. Do those small group training sessions way out in the field. Look for the employees who are holding back, or sitting defiantly with their arms crossed, or any of the other signals you should be looking for. After the training invite that person to have lunch with you. Listen, listen, listen. In the real world most people seem to never have anyone actually LISTEN to them. If you do that, and you are patient, people will tell you all types of things – they can finally open up to someone who is actually listening to them.

    Finally a word on motivation. In my experience, employees often care deeply about their company, their work unit, and/or their teammates. When someone in the company is doing wrong things, they are often genuinely angry, but believe no one cares. Seek them out, listen to them and then act. Word will get around and you will establish the credibility necessary to be effective.

  5. The concept of, having the ability of anonymous reporting as somehow sending the wrong message, is disingenuous at best. The "message" that it's not safe to come forward with issues, is the reality of many, probably most, workplaces, and employees know it.
    Having front line managerial experience for years, I can offer the following:
    If employees trust you, they will tell you everything – good, bad and ugly. The ugly makes it easier for you to do your job, not harder.
    Second, employees are incredibly savvy to management insincerity. They soon learn when managers solicit feedback for all the wrong reasons, and they adapt accordingly. You don't want that. You don't want yes-men and yes-women. Ah, but most leaders do, I'm afraid.
    Third, poor management teams consistency underestimate the intelligence of their employees.
    Treat your workers at all levels as your intellectual equal – it will pay dividends.

Comments are closed for this article!