What the CFO's Are Reading:
Don’t Discount Secondhand Whistleblower Reports
Research
shows: Reports based on Secondhand Information
More Credible than those from Firsthand Knowledge
Which employee whistleblower hotline report would you trust more — one with
firsthand knowledge of alleged conduct or one based on secondhand information?
After examining more than 2 million whistleblower reports from more than
1,000 publicly traded U.S. companies, our new study found that secondhand
whistleblower reports are almost 50% more likely to be substantiated —
in other words, they’re 50% more credible — than firsthand
reports.
With organizations around the world increasingly adopting risk management
mindsets, this is a crucially important, counterintuitive finding. It should
turn the heads of company leaders who might have looked askance at secondhand
reporting in the past.
Secondhand reports often hold untapped approaches to discover organizational
problems, or even prevent problems from happening in the first place.
Why Secondhand Reports Are More Valuable
We reached out to some chief compliance officers whom we knew were at the top of
their professions and whose organizations use integrated compliance and risk
management systems. They actually weren’t surprised when we shared our research
and pointed to two primary reasons for the greater credibility of secondhand
reports.
One reason is that firsthand reports are more likely to be frivolous and are
occasionally personally motivated. Secondhand reporters who decide to come
forward usually do so after doing a sort of first round of vetting of the
situation themselves. In other words, a secondhand reporter is most likely
going to say something only if they’re sure about what they’re reporting.
Second, many valid firsthand reports are never made, because those affected
sometimes fear retaliation or blowback. This is less of a concern for
secondhand reporters — because they aren’t personally as involved, they
don’t have as much to lose.
Further
Dissecting Firsthand and Secondhand Reports
Our analysis, which covered reports made between 2004 and 2017, found that
firsthand reports were more frequently made in person, more frequently
involved reports of human resources issues such as harassment and
discrimination, and contained more details.
Secondhand reports were more likely related to accounting and
financial concerns and business integrity issues.
Firsthand reports were more common; of the reports where a source’s awareness
level — i.e., whether they were firsthand or secondhand – could be identified,
44.3% were made by someone directly involved and 20.6% came from a firsthand
witness. Just under 15% could be classified as secondhand, from either an
employee or someone outside the company.
At first glance, this relative paucity could give already skeptical company
leaders more reason to look past secondhand reporting. But our findings showed
not only the credibility of the reports, but that they correlated with results
that any executive should encourage.
More secondhand reports from employees corresponded to fewer lawsuits and lower
legal settlements in the following year. Secondhand reports from individuals
outside the organization were negatively associated with the number and dollar
amounts of government fines in subsequent years.
We didn’t find the same correlation with firsthand reports.
What Should Companies Take From This?
After spending the past couple of years digging into whistleblower hotline data,
I’ve come away with one conclusion:
Whistleblowing is the best thing that is never talked about in the right
way.
It’s almost always viewed negatively, probably because when the public at large
sees something stemming from a whistleblower report, it tends to be associated
with a scandal, or at least negative publicity.
But that’s usually because a whistleblower’s initial flagging of the problem got
dismissed or ignored, and a larger problem took root and eventually was made
public. Either way, the thinking around whistleblowing needs to change.
Recent
research has shown that increased internal hotline use correlates with
greater profitability and workforce productivity (as measured by return on
assets), fewer material lawsuits brought against the company overall (and lower
settlement costs if a lawsuit does occur), and fewer external whistleblower
reports to regulatory agencies and other authorities.
These findings show that a high volume of reports indicates a healthy
organization that effectively encourages communication among its employees.
The findings show that old thinking that still exists in too many C-suites and
boardrooms — less reporting equals fewer problems — is wrongheaded. And this
latest research shows that dismissing secondhand whistleblower reports out of
hand falls in the same category.
Given these new lessons, and the financial repercussions that are at stake when
it comes to lawsuits, regulatory fines, and bad publicity, boards should seek
out more hotline reporting information. And compliance officers should strive to
make board members understand the valuable intelligence these reports offer —
even when they’re secondhand.
Kyle Welch is an assistant professor of accountancy at The George Washington
University School of Business.
cfo.com