How to create a successful SpeakUp programme: 8 Steps
This guide offers a concise overview to help your organisation build a robust, effective SpeakUp culture.
These 8 elements are designed to provide a comprehensive framework to cultivate a proactive SpeakUp culture. We aim to shift the focus from a risk-averse, legalistic approach to one that prioritises open communication and ethical integrity.
8 key elements for a successful SpeakUp programme
1. SpeakUp culture
The first component of a SpeakUp Programme is establishing a "SpeakUp Culture." This means creating a working environment where employees feel free to speak up. This concept is closely related to psychological safety, which Amy Edmondson discusses in her book "The Fearless Organisation" (2018). Psychological safety is crucial for fostering growth and innovation within agile working environments.
A SpeakUp Culture ensures that employees feel safe to raise ethics-related concerns. However, open communication can only thrive if the broader organisational culture supports it. Investing in a psychological safety net is essential for this process.
While prioritising psychological safety and an open SpeakUp Culture, it's crucial not to underestimate the difficulty of speaking up. Leadership can play a vital role in modelling and praising those who speak up.
The SpeakUp Programme should be part of your Code of Conduct. It should provide options for reporting misconduct and serve as a reinforcement tool. Emphasise the importance of speaking up and listening within your Code of Conduct. This cultural element should be integrated into HR onboarding, the HR cycle, and other cultural programmes.
To maintain open dialogue, clarify that the SpeakUp tool is a safe channel. It's also a way to ask sensitive questions anonymously, helping victims or witnesses to understand their rights when reporting.
Creating a SpeakUp culture is a continuous effort but vital for a transparent and ethical organisation.
Key points
- Promote and facilitate open dialogue.
- Integrate the SpeakUp tool as a part of your Code of Conduct, HR onboarding, and company culture.
- Encourage positive role modelling.
- Praise and acknowledge those who speak up.
2. Purpose-Focused
The second component of a SpeakUp Programme is “purpose-focused.” This means never losing sight of the actual purpose behind introducing a SpeakUp tool. While we don't dictate your organisation's specific objectives or intentions, we do emphasise that focusing on the wrong elements can lead to an ineffective SpeakUp Programme, jeopardising its essential early warning mechanism.
One common misfocus we encounter is an overemphasis on legal compliance. While compliance is crucial and often the initial motivation for introducing a SpeakUp tool, such as with the EU Whistleblowing Directive, it should not overshadow the primary goal: early transparency through speaking up. Legal jargon, formal processes, and intimidating labels like ‘whistleblower’ can deter employees from speaking up, making the programme ineffective.
Another pitfall is focusing too much on creating formal whistleblower reports or cases. The main purpose of a SpeakUp Programme should be early transparency to prevent or detect ethical wrongdoing as soon as possible. A low-barrier procedure and a safe cultural environment where employees can talk to managers early on are invaluable. Although less measurable, this approach prevents damage more effectively.
Finding the right balance between focusing on the information and the person making the report is tricky. The golden rule in whistleblowing is to focus on the facts, not the whistleblower. This fundamentally protects whistleblowers. For instance, one organisation chose not to disclose that a compliance case was initiated by a whistleblower, which is the ultimate form of protection.
However, focusing on the facts should not compromise the report’s integrity. In the initial communication, avoid overwhelming the reporting employee with excessive fact-finding questions or lengthy questionnaires, as this can deter them. Building trust during this phase is crucial. Limit the initial questions to avoid losing the reporter entirely.
In summary, maintain a purpose-focused approach in your SpeakUp Programme to ensure its effectiveness and long-term success.
Key points
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Acknowledge that the ultimate purpose of such a programme is to create transparency in order to put a stop to wrongdoing
- Legal compliance should be the baseline, not the sole focus.
- Avoid creating an environment focused solely on compliance and formal processes.
- Protect whistleblowers by focusing on the facts rather than the identity of the reporter.
- Ensure your programme is preventive and protective.
3. Ease of use
The third component of creating a SpeakUp Programme is 'easy'. It's vital to make it straightforward for employees to find guidance and a listening ear. While this seems logical, details matter. Any complexity can deter employees from reporting, leading them to stay silent, leave the company, or even become complicit.
An effective SpeakUp Programme creates momentum. When an employee gathers the courage to report, someone must be ready to listen. Listening can be challenging for busy managers. Imagine an employee, who notices unusual behaviour. During their bi-weekly meeting with their manager, the employee hints at their concern. Manager, , overwhelmed with other tasks, dismisses it. The em ployee is unlikely to bring it up again.
SpeakUp tools are designed to facilitate such momentum. They ensure that when someone wants to speak up, someone is always there to listen. The tool should be accessible 24/7 via phone and web, and it must be user-friendly and anonymous. Simplify the reporting process. Have one central intake point with clear responsibilities, without overloading employees with options.
Focus on positive, clear communication. Avoid legal jargon and complicated procedures. Embed the programme into existing workflows to make it familiar and user-friendly.
Remember, speaking up is difficult. Always consider the perspective of those who have something to report when designing your SpeakUp Programme.
Key points
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The SpeakUp Programme should facilitate momentum
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Create this momentum by having a safety net in place: a low barrier tool like a SpeakUp
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Easy tool (24/7, multiple channels, easy UX)
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Avoid an initial overload of questions
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Multilingual in all its steps
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Anonymous reporting
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Easy, simple, front-end flow
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Scope of the SpeakUp programme should include any suspected breaches of the Code of Conduct
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Focus on activating the first step of a silent witness
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Focus on building trust
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Create clarity regarding the procedure
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No legal or complex terminology
4. Balanced anonymity
The fourth component of a SpeakUp Programme is 'Balanced Anonymity’. This involves ensuring anonymous reporting while mitigating any negative consequences. Anonymity is essential for creating low barriers and ensuring reporters feel safe. However, while it's widely accepted among compliance professionals, it's also controversial and may be perceived as fostering a 'snitching culture'.
Anonymity concerns are rooted in the potential misuse of the system, false accusations, and the fear of undermining a SpeakUp culture. When implemented correctly, anonymity and a SpeakUp culture can complement each other.
Balanced anonymity involves using anonymity as a last resort when no other reporting methods are perceived as viable. This principle lowers the barriers for witnesses to speak up. Anonymity provides the reporter control and protection, which confidentiality alone cannot guarantee. It's crucial for reporters to control how much information they share, as even anonymised contexts can reveal identities.
Communication with anonymous reporters is vital for follow-up questions and building trust. Anonymity can be temporary or just one part of building a case. Protecting the accused is equally important. Anonymity should be viewed as a supporting element. The SpeakUp Office must safeguard the accused, and a procedure should be in place for handling anonymous reports.
Focus on the message, not the messenger. If other evidence supports the anonymous message, consider removing references to the anonymous report to protect the whistleblower. This takes courage but is crucial for protecting the reporter.
Balanced anonymity ensures that your SpeakUp Programme is both effective and fair.
Key points
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Understand the concerns that might exist regarding anonymity
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Position anonymity as part of the SpeakUp programme
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Position anonymity as a last resort
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Use anonymity as a way to enable the first step in activating the silent voice
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Offer anonymity in combination with control at the reporters side
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Build trust, protect the reporter who might want to come forward
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Find supportive evidence of the fact mentioned
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Focus on the message, not on the person
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Protect the accused
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Professional handling and procedures
5. Safety
The fifth component of a SpeakUp Programme is 'Safe'. This pertains to the necessity for confidentiality and safety within the programme. A SpeakUp Programme should protect the reporter, the accused, other involved parties, the organisation, and ultimately, society.
Protecting the reporter, is best achieved by not drawing attention to them or the act of reporting. This requires a specific mindset, materialised through procedures and communications. Anonymity is one way to protect the reporter. It also safeguards the accused by allowing for follow-up and verification questions.
It's crucial for reporters to communicate in their native or preferred language. This ensures they are in control of the conversation and the information shared. Not pressuring reporters into sharing information also contributes to their protection.
The accused and other involved parties are protected through professional and confidential follow-up procedures, clear data deletion policies, and a firm stance against the misuse of the SpeakUp Programme. Clear communication about the process is essential. Support mechanisms for accused employees should also be defined, providing them a place to turn for help.
Ensuring safety within the SpeakUp Programme is vital for building trust and encouraging honest reporting. This comprehensive approach safeguards all parties involved and reinforces the programme’s integrity.
Key points
- Protect the person speaking up
- Protect the person who is accused
- Protect other implicated persons or witnesses
- Offer anonymous reporting and emphasise dialogue
- Consolidate all messages from all sources into one database for monitoring
- Ensure system and data storage security
- Implement a clear user access and defined role matrix
- Assign the right people for the job
- Prepare for a confidential, safe fact-finding and follow-up process
- Provide clarity on the process, including protection limitations
- Ensure transparency about the safety of the system
- Ensure the reporting person is in control
- Invest in solid, secure internal reporting to avoid external disclosures
- Create a feedback policy and provide clarity on it
- Filter and anonymise content appropriately before sharing (need-to-know basis)
- Actively filter information from anonymous SpeakUp tools
- Seek and find supporting evidence quickly to shift focus to the facts, protecting whistleblowers
- For ultimate protection, eliminate evidence of a whistleblower’s involvement by focusing on facts
- Include serious consequences for any misuse of the SpeakUp Programme as a breach of the Code of Conduct
6. Governance
The sixth component of a SpeakUp Programme is ‘Governance’. This involves the crucial allocation of resources, accountability, workflow, and having the right people on the job. Proper organisation ensures readiness when a SpeakUp message comes in and minimises the risk of mishandling a case. Having dedicated and knowledgeable personnel is a good start.
Clearly defining the workflow and governance is the first step. The workflow starts with the 'entry point', which should be clear and simple for employees or other concerned parties. As discussed in component 3 'Easy', the front-end of the workflow should not be overcomplicated. There should be one central intake point with clear responsibilities to build trust and activate the first step for a silent witness.
At the receiving end, it is important to differentiate between intake and action takers. The intake should be small and centralised, while action takers should be selected based on their expertise, experience, and professionalism. The intake office or managers (SpeakUp office or SpeakUp managers) have a central role in the case handling process. They monitor the programme, manage policies and procedures, and handle triage. They onboard and assign specialists (action takers) and are responsible for protecting all involved parties, ensuring confidentiality at every step. The intake function should be distinct from the expert action taker role.
Roles to be defined and appointed include:
- The body responsible for conclusions after investigations
- The body responsible for making decisions regarding consequences (including sanctions)
- The body responsible for closing a case
- The body responsible for clearing information
Ethics committees may also play a role, and their exact functions can vary. High-level discussions of cases, patterns, and statistics are essential for making preventive and strategic decisions.
The 'investigations' part is critical, involving fact-finding and seeking supporting evidence. Some organisations include pre-investigations for early fact-finding. Investigations should be carried out with prudence by trained professionals to avoid damaging the programme's reputation.
Strong governance ensures the SpeakUp Programme runs smoothly and effectively, protecting all parties involved and maintaining the integrity of the process.
Key points:
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Define and set up a (centralised) intake function
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Define action takers (make or buy)
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Make sure there is clear user access and defined role matrix
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Assign the right people for the job
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Prepare for confidential, safe fact-finding and follow-up process
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Map the potential action takers, also consider ‘make or buy’ (i.e.consider hiring external experts on an ad hoc basis)
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Prepare for fact-findings (pre-investigations) or investigations
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Have an investigation policy or protocol in place
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Have the applicable procedures in place (“whistleblowing policy” > “SpeakUp policy”)
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Have the basics of process and procedures summarised in easy formats to share with employees
7. Story
The seventh component of a SpeakUp Programme is ‘Story’. This refers to the power of effective semantics and communication in managing the programme.
Before launching your SpeakUp tool, consider how to frame it. Ask questions like: Why is this tool important? What benefits does it bring to employees, partners, and the organisation? How does it fit into our culture? These questions are crucial for starting the programme with consistent and convincing branding. Effective communication will encourage more people to utilise the SpeakUp programme. The best message aligns with existing company principles, objectives, or the code of conduct.
We recommend positive branding. Avoid terms like ‘whistleblowing’ which have negative connotations. Instead, refer to it as a SpeakUp Programme. This focuses on transparency and early detection of ethical wrongdoing. While the EU Whistleblowing Directive has renewed interest in using the term 'whistleblowing' to show legal compliance, we suggest minimal use of formal and legal terminology in your communications.
Put formal statements and procedures in a document, but avoid using them towards potential reporters. Use summaries, FAQs, or short videos to communicate the process of making a report, follow-up, and responsibilities. Clear communication encourages reporting, but over-complicating the process can deter potential reporters.
Finally, tailor the story to fit your organisation. Positive framing of the SpeakUp Programme, as described in component 1 ‘SpeakUp Culture’, typically yields better results.
Key points:
- Develop a positive, fitting narrative that aligns with company values.
- Avoid using terms like “whistleblower” and legal jargon.
- Provide clear, concise, and user-friendly guidelines.
- Use reporting personas to tailor communication strategies.
8. Build, Measure, Learn
The eighth component of a SpeakUp Programme is "Build, Measure, Learn". This highlights that the programme is an ongoing journey. Launch with the minimum requirements to ensure you are prepared enough to handle messages properly; one poorly handled message can damage the programme's reputation.
Continuously monitor your KPIs and statistics to identify areas for improvement and expansion. Report publicly on the results and challenges of the SpeakUp programme, demonstrating transparency and commitment. Internally, share more detailed, anonymised case examples that show how SpeakUp reports led to positive changes. Praise those who reported and maintain continuous communications to build trust.
Seek sponsors and promoters within your organisation to champion the programme. Collect data not only from the system but also from other sources. Scrutinise exits to gather valuable insights. Keep the programme active and positive, making it clear that it exists to support and help employees.
Ensure your organisational message fits well with the programme, repeat it, and embody it consistently. This approach will build trust and encourage more people to speak up.
In summary, building a successful SpeakUp Programme involves continuous improvement. Monitor key metrics, share successes, address challenges transparently, and engage with employees to make the programme a trusted and integral part of your organisation.
Key points
- Monitor KPIs and feedback to identify areas of improvement.
- Publicly report on programme outcomes to build trust.
- Share anonymised success stories internally.
- Promote the importance of speaking up consistently.
Successfully embedding a SpeakUp culture in your organisation is achievable by focusing on these critical components. Remember, building such a culture is a journey that benefits from continuous learning and improvement. Engage your team, protect your reporters, and foster an environment where ethical transparency is paramount.