Episode Transcript
[00:00:11] Speaker A: Here at Ethisphere, we believe there is no competition in compliance. That's why we are using this show as a platform to answer high level questions about business integrity that have been posed to us by the members of the Business Ethics Leadership alliance, or bella. Bella is a global ethics and compliance community that provides exclus exclusive access to helpful data, benchmarking events and other resources to advance your ENC program.
It also provides a concierge service by which members can submit questions around best practices and our internal experts will provide an answer plus helpful resources with more information.
Many of these questions are particular to a specific company's needs, but many more of them speak to challenges or opportunities that face ENC professionals everywhere. So in this episode, we're going to answer one such question as part of our ongoing mission to make the world a better place by advancing business integrity.
Joining us once again to answer these questions is Bella chair Erica Salmonburn. Erica, as always, it's great to see you on the program. Thank you very much for joining us.
[00:01:11] Speaker B: Oh, Bill, thank you so much for having me. And, and one of the things that I was excited about coming back for this particular question about was it really does kind of be a through line for, from the, from, from some of the investigation ethica spell asks that we've done over the course of the last year and a half. This is one of those questions that was like the one thing we didn't quite get to. So I'm really excited that we had a member ask us this one.
[00:01:34] Speaker A: Well, it is an investigations question, as you mentioned, and it reads, and this is a good one. What strategic purpose should my investigation's substantiation rate be serving?
[00:01:42] Speaker B: Yeah. So your substantiation rate, Bill, is basically the rate compare the if you take your overall number of issues that come into your, whatever your case management system might be, and I would caution everybody listening to us that has not already listened to, how should I be thinking about my intake methods? How should I be triaging my investigation protocols? How should I be thinking about root cause? Right. All of those Bella asks, that Bill and I have done over the course of the last year, they all fit inside of this particular thing. So however it is that your issues are coming in, whether it's through your managers, your hotline, direct outreach to your ethics and compliance team, your HR business professionals, one of the things you should be tracking is how many of the things being raised to me turn out to be accurate. Right. How many times does my team find themselves in a position where they don't have enough information to say, yes, this thing that was alleged has happened. And there's a lot of different things, strategically, that your substantiation rate over time is going to be able to tell you. One is going to be, how do I think about substantiation rate differences based on which investigators are looking into an issue? Are there particular types of issues that get raised that are more likely to be substantiated than others?
Is there a substantiation difference based on whether something is raised anonymously or if I know who the person raising the concern is, might be, how am I looking at my substantiation rate by location? So are there particular parts of my business where I find it's really challenging for me to say, yes, this thing that was alleged happened. And then one of the other things that I like seeing companies do, Bill, that we have started to see over the course of the last couple of years more and more is companies looking at their substantiated and unsubstantiated cases in the aggregate and asking themselves for the unsubstantiated ones in particular, what caused this person to raise this concern? Right. I was able to substantiate that misconduct happened. I was not able to substantiate that discipline was warranted, but someone felt like something wasn't right. So I'm going to raise my hand.
And what was that thing? One of the stories that I've told often when I speak on these topics, Bill, is I was talking to a compliance officer many years ago, and they kept getting calls to the hotline from this one particular location. And it was individual employees of a factory complaining about the food in the cafeteria, calling the hotline, calling the hotline. The food is, you know, the food's dreadful. The food's making me sick. The food, the food, the food.
Finally, the general counsel comes to the compliance officer and says, look, I know it's not a code issue. Just get out there and figure out what the heck's going on with the food. Like, go to the cafeteria and see what might be happening.
And so general counsel gets on a plane, flies to the country of at issue, gets off the plane. And it turns out employees were calling about the food because the manager at that particular factory was taking their identification papers when they arrived at work and not letting them to have them back until they had achieved certain milestones from a production perspective.
So he thought it was a cafeteria issue. It turned out to be a slavery issue. Right. A human trafficking issue.
And so that is my cautionary tale for unsubstantiated concerns because before he got on the plane, like they would call the caterer, no, no, no, everything's fine. Nobody's complaining about the food. Like, everything's fine. Turns out he had a much, much bigger issue. So. So substantiation versus non substantiation is absolutely something you should be thinking about strategically and looking at that data to say, what else is this going to tell me about what may potentially be happening in my business?
[00:05:33] Speaker A: Well, Erica, as always, very, very grateful for you to come onto the program and answer these questions. This time was a great question, fantastic answer. But also thank you for sharing that deeply compelling story because it's such a powerful real world example of, of how these things have an impact and why they matter. So thank you very much for sharing that.
[00:05:50] Speaker B: Yeah, no, absolutely, Bill, my pleasure. And to the Bell member who brought us this particular question, thank you for completing our investigation.
I don't even know if it's a trilogy at this point, Bill. I feel like we've answered investigation questions, you know, across six or seven different questions, but this was one we hadn't gotten to yet. So thank you for. Thank you for bringing it forward.
[00:06:10] Speaker A: To learn more about Bella, visit Visit@the sphere.com Bella to request guest access to the member resource hub and to speak with the Bella engagement director. If you have a question you would like answered on this program, contact the Bella Concierge service and we'll get to work on it for you right away.
This has been another Bella Asks episode of the Ethicast. Thank you so much for joining us and we really hope that you've enjoyed the show. If you haven't already, please like and subscribe on YouTube, Apple Podcasts and Spotify.
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That's all for now, but until next time, remember, strong ethics is good business.
