The second scenario is especially
problematic. Even if an organization does a
good job controlling the threat of retaliation
against internal reporters, there might still be
the question on whether a company’s “culture”
allows the behavior being observed.
Which brings us back to the topic of what
goes on in the mind of the reporter.
Managing the reporter’s expectations
I have corresponded with more than 500
internal reporters over several years. Most
of them were, and will remain, anonymous;
therefore it is virtually impossible to try to
categorize the reporters’ motivations. But one
aspect is always certain: an internal reporter
(or whistleblower) will have a preconceived
expectation about how the information he or
she provided will be used.
This is the reason why you, the compliance
professional, will play an important role. The
manner in which you manage the initial contact
will determine to a great extent what the
reporter can expect from the report.
Communicating with the reporter
We cannot assure the reporter that corrective
action will be taken, as this would imply that
the report had full merit. Conversely, we cannot
advise the reporter that no policy is being
violated, as we can almost never be sure if he or
she has provided all information available.
The safest way to approach the initial
communications with internal reporters is
under the assumption that everything you
respond with could one day become public.
Clearly, an anonymous reporter is not going
to ask for your permission before posting
your responses (including voice messages) on
How do we respond then? It is much more
positive, safe, and productive to assure the
reporter that the information has been received
and that it will be investigated.
Some reporters do press for answers,
wanting to know the outcome of an
investigation. Unfortunately, if the reporter
has remained fully anonymous, it is not
recommendable to outline what was done. You
do not know if the reporter might be one of
your competitors or an overzealous member of
You can set a tone of trust by advising the
reporter that the information received will be
investigated and that your organization does
not tolerate retaliation against internal reporters.
For reporters that insist on remaining
anonymous, it is always recommended to
remind them that it is their responsibility to be
careful with whom they discuss the information
they have. They can also be cautioned about
conducting their own inquiries, as this may
compromise an investigation and attract
attention that may undermine their anonymity.
What motivates a whistleblower?
It is essential for you, the compliance
professional, to remember that there could be
numerous factors and interests that motivate a
reporter. These could range from goodwill and
ethics, to sense of justice, to vindictive intent,
among others. You should be comfortable with
the idea that, many times, you will not know
what finally moved a reporter to speak up.
Understanding that anonymous reporters
might be motivated by different interests will
help you keep your mind open to assess, in an
objective manner, the information you receive.
By managing the reporter’s expectations,
establishing reasonable communication
parameters, and understanding what
motivates reporters, you will be in a better
position to make the most out of ethics and
anonymous reports, and ensure a meaningful
contribution from the compliance function in
your organization. ✵
Miguel Rueda ( firstname.lastname@example.org) is Sr. Audit Manager—General
Compliance at Air Canada in Winnipeg, MB.