Multiple types of wrongdoing reported in the one complaint are referred to as a ‘mixed’ complaint. This can sometimes add complexities to complaints that require responses from different parts of the business, such as People and Culture and/or Legal and Risk.
The ISO 37002 standard on Whistleblowing management systems (ISO) released in 2021 notes that a single whistleblower report can include information about multiple types of wrongdoing. The ISO goes on to explain that there needs to be good coordination between an organisation’s whistleblower management system and other systems that may handle different types of alleged wrongdoing.
A study in 2019 titled “Whistling While They Work 2” by Griffith University further supports these observations. The study analysed reports from over 5000 reporters and 3600 managers and governance professionals. The study revealed that a high proportion of complaints make up both integrity or whistleblower matters as well as personal or workplace grievances. These reports also had a high proportion of whistleblower and other personal or workplace grievance complaints ‘mixed together.’ 70% of the reports involved integrity issues, but over half of these reports (42%) also had workplace issues contained within them.
Our experience at PKF Integrity is consistent with ISO and the Griffith University study, in that we regularly manage whistleblower and broader conduct complaints that have multiple types of wrongdoing contained within them. We also find that although many different types of integrity related complaints need to be received, assessed and responded to holistically, a holistic approach is not occurring in many organisations. Different stakeholders are responsible for different types of complaints.
The mixing together of different wrongdoing types in one complaint is testing whistleblowing and other complaints management systems. We find that poor performing IT and complaints management systems, capability shortages and a complex regulatory landscape further compound the complexities for managing whistleblower and broader conduct complaints.
Whistleblower complaint management models now being discussed by recent reports into workplace culture are going a step further than the traditional internal investigative unit, or independent hotline. The work undertaken by Elizabeth Broderick & Co in the “Report into Workplace Culture at Rio Tinto” (the Rio Report) talks about the need for a discreet unit, with independent operation, to maximise trust in the process and encourage greater reporting. Such a unit is designed to be victim-centric and work closely with both the organisation and the complainant to seek effective resolution.
The research findings are consistent with our own experience in this space. Future success for organisations is a good balance and close connection between the internal and external reporting frameworks. Some whistleblowers will not want to talk to anyone inside the business about what they are experiencing or witnessing. To ensure best outcomes for all, an internal reporting framework process must work closely with the external reporting options. David Morgan, Partner PKF Integrity
Independent whistleblower solution
An external whistleblower and complaints management service provides confidentiality, and if required, anonymity, to staff members thereby increasing the likelihood of concerns or complaints being lodged in a timely manner.
An expert, independent whistleblower and complaints management solution assists with managing the complexities of legislation that applies to protect employees who report wrongdoing.
At PKF Integrity, we specialise in managing whistleblower and other types of conduct complaints with the added benefit of an independent whistleblower and conduct complaints management system.
