Guidelines for the Development of an Ethics Safety Net

ABSTRACT. Large organisations are especiallyadvised to consider the possibility of an EthicsHelpdesk in which

all employees and managers canreport all suspected cases of unethical conduct, criticalcomments, dilemmas and advice for which there isinsufficient room within the organisational hierarchy.A helpdesk is a central contact point where it isdecided who the most appropriate person is to dealwith a given case. The helpdesk model is characterisedby low barriers in its easy accessibility, positiveapproach and the simple procedures employees needto follow. It offers employees consistent support whilerelying on the responsibilities of the individualemployee as much as possible and it facilitatesadequate monitoring and reporting. A helpdeskincreases the chances of detecting unethical conductwhich enables management to take adequate andtimely measures against improper conduct. This articleformulates principles, discusses critical factors andconsiders three models for adopting a sound andintegrated ethics safety net. It also presents a casestudy and shows why organisational openness needsto be institutionalised.

KEY WORDS: codes of ethics, culture, ethicshelpdesk, ethics officer, ethics management, internalethics safety net, whistle blowing

Introduction

The introduction of the business code of ethics(see, for example, KPMG, 1999a, b, c, d, 2000;London Business School & Arthur Anderson,2000; Weaver et al., 1999) has increased the needfor companies to detect non-compliance withcodes and to take the appropriate measures.Regardless of how well a code is embedded, thepossibility of unethical conduct remains. Only inan ideal world unethical behaviour does not exist.The more ambitious the norms and values for-mulated by the code, the greater the likelihoodthat incidents will erode the credibility of thecode and of the company itself, with all theconsequences that may ensue. It is thereforeimportant that working relationships contain self-regulating and self-correcting mechanisms againstunethical conduct (see Table I for some benefitsof timely detection of unethical conduct). Manycodes therefore, encourage employees to chal-lenge each other on unethical behaviour and toinform the manager if required (e.g. GeneralElectric and General Motors). An ethics codemakes it easier for employees to challenge eachother, but also offers management grounds forchallenging employees and imposing sanctionswhen necessary. As follow up to a code, compa-nies often also implement management systemsin order to detect unethical conduct early (EthicsResource Centre, 1994; KPMG, 2000; Weaveret al., 1999).

The extent of unethical conduct is not theonly information that is relevant in the assess-ment of the ethics of a corporation. The extentto which the organisation tries to prevent uneth-ical conduct and whether it addresses unethicalconduct adequately is just as important. The

Guidelines for the Development of an Ethics Safety Net Muel Kaptein

Journal of Business Ethics 41: 217–234, 2002.© 2002 Kluwer Academic Publishers. Printed in the Netherlands.

Dr. Muel Kaptein is a Senior Consultant at KPMG Ethics& Integrity Consulting and is Director of Ethicon, theCentre for Ethics Management at Erasmus UniversityRotterdam. He has been involved in the developmentand implementation of various projects to institutionalisewhistle blowing, including the KPN Telecom helpdeskdiscussed in this article.

ethical content of a corporation, as defined byKaptein (1998, 2000), consists among otherthings of the extent to which unethical conductis internally visible (the corporate virtue ofvisibility), discussible (the corporate virtue ofdiscussability) and sanctionable (the corporatevirtue of sanctionability). Also, Bird (1996)stresses the moral duty of corporations to preventorganisational blindness and deafness: i.e. notseeing or hearing the unethical conduct andethical dilemmas of its employees. Practice,however, reveals that employees encounterobstacles to challenging each other and theirmanagers and vice versa (like those mentioned inTable II), which hinders corrective measures frombeing taken. Fifty-five percent of the Americanworking population experience barriers to chal-lenging each other or their manager (KPMG,2000). As long as these barriers exist and uneth-ical conduct cannot be adequately discussed withimmediate colleagues and the manager, it isnecessary that organisations have an internalsafety net which circumvents the usual hierar-chical channels through which employees canreport incidents. An internal ethics safety net can

be defined as all the corporate institutions andfunctionaries where employees can raise issueslike incidents and dilemmas outside of the hier-archical line of management.

Larger organisations in particular often have aninternal ethics safety net. In addition to line man-agement, they could for instance have a compli-ance officer against the misuse of insiderinformation, company security against theft andcriminality, and a counsellor for intimidationand aggression. Over and above this, companiesusually have occupational social workers, occu-pational doctors, staff councils, auditors, internalreview boards, and legal advisers employees cancontact. Employees can often also contact thePurchasing department (e.g. in connection withissues relating to blackmail, corruption andexerting unacceptable influence during negotia-tions), the Environmental department (e.g. withregard to illegal dumping, waste of resources andnoise pollution), the Customer department (e.g.in connection with selling harmful products,intimidating consumers and neglecting consumercomplaints) and the IT department (e.g. withregard to downloading undesirable information,

218 Muel Kaptein

TABLE IPossible benefits of adequate detection of unethical conduct

Detection of incidents can result in:– Limiting the damaging effects of the violation or breach of conduct. For instance, early identification of a victim

of bullying could prevent long term absenteeism as a result of psychological complaints.– Reducing the chances of repeat behaviour by the same person. If a perpetrator gets away, the chance of repeat

behaviour increases. The threshold, after all, gets lower and lower.– Reducing the chances of more serious violations by the same person. Serious criminals often start out as petty

thieves. If a violation is turned a blind eye, the perpetrator will have fewer moral objections to committinga more serious offence the next time.

– Preventing the degeneration of the corporate culture. Leaving undesirable behaviour uncorrected can create theimpression that the organisation is not that serious about compliance. The attitude of “Why should I beholier than my colleague?” could lead to copycat behaviour.

– Correcting the violation, thus emphasising organisational norms. That which is tolerated reveals the actualnorms of the organisation. A manager that challenges employees on excessive use of the telephone forprivate calls during business hours creates a norm. In contrast, unchallenged violations actually underminethe credibility of the norms in question.

– The possibility of violations being reduced altogether. Timely detection and counter measures have apreventive effect. The realisation that unethical conduct is not only detected but also addressed works as adeterrent. Often, violators who have been caught confess that they thought they could get away with it.

– The possibility of implementing a preventative policy. If no lessons are learnt from mistakes or inadequaciesin the organisation, the chances are that similar incidents may occur elsewhere in the organisation.

visiting dubious sites and sending offensiveemails).

Employing a lot of different service points forreporting ethical issues involves risks. First of all,service points may not be prepared for dealing withemployees who have something to report, whileemployees may assume that they are. Secondly, asa result of a multitude of services, the safety netmay become obscure, which means that employeesdo not know where to go to with whichquestion. A third risk is that the safety net offersinsufficient coverage of the issues with whichemployees are confronted. If there is no service

point for reporting a matter that is not officiallyidentified, the employee will end up being sentfrom pillar to post. Similarly, there is the risk ofinsufficient coordination between the service points.This may happen as a result of, for example, alack of liasing between compliance officers orconflicting standards. Or due to the Securitydepartment’s mediation of a sexual intimidationcase (because the incident is reported as a caseof damage to corporate property when the victimtries to take revenge), without (as the true stateof affairs comes to light) involving or informingthe counsellor who is formally responsible for

Guidelines for the Development of an Ethics Safety Net 219

TABLE IIObstacles to challenging unethical conduct

Obstacles to challenging a colleague on unethical conduct include:– The person who challenges is dismissed as being a busybody, know-all or moralist.– The stone is cast back by pointing out the shortcomings of the challenger.– The perpetrator threatens with counter actions.– The perpetrator believes that everyone does it and that s/he should not be blamed for it.– The perpetrator admits to having acted wrongly, but does not accept the consequences of the action.– The perpetrator believes s/he is entitled to appropriating company resources.

Obstacles to informing the manager of unethical conduct of a colleague include:– The employee is seen as a telltale (or thinks that s/he is seen as a telltale), thereby undermining team

solidarity.– The manager believes that s/he is quite capable of detecting unethical conduct and does not depend on the

help of colleagues to do this.– The manager tells the staff member to go back and sort out the problem him/herself.– The perpetrator undertakes undermining actions or starts a counter offensive.– The manager wants to avoid the risk of the incident opening a Pandora’s box.– Due to confusion as to which norms exactly are involved, grounds lack for challenging the perpetrator.– The manager is personally involved in the incident and wants to save his or her skin by sweeping it under the

carpet.– The manager is partly responsible for allowing the incident to happen and does not wish this to come to

light.

Obstacles to approaching higher management include: – Raising the issue is seen as a motion of no confidence in colleagues and the manager.– Raising the issue is seen as betrayal of the group.– The higher echelons send the employee back because they do not feel responsible for problems in the lower

echelons.– The higher echelons do not have the time or priorities to pay attention to similar issues.– The more the violation forms part of the culture of the organisation, the less inclined the higher echelons

will be to deal with it. Swimming against the stream is therefore no attractive prospect for the employee inquestion.

– Employees are often not clear about the relationship between their manager and his/her superior: do theyget along very well, or is it a potentially explosive relationship? In either case, a report can have a contraryeffect and the reporting employee has no guarantee that the issue will be dealt with the necessary care.

resolving sexual harassment cases. Finally, the riskexists that the board lacks a clear overview of allincidents. An incident can, for example, gounnoticed or it might get counted twice becauseit gets manifested in more than one channelwithout management realising it concerns oneand the same matter. If an ethics safety net isnot sound, it can lead to perpetrators remainingunpunished, the increased possibility of a recur-rence, the culture degenerating and employeeslosing confidence in the company. This resultsin poor achievements and even in their leavingthe company (the exit option as described byHirschman (1970)). Another possible repercus-sion is that employees report incidents externally(so-called external whistle blowing or the voiceoption which Hirschman (1970) speaks of ),bringing the organisation into discredit. Anempirical study by Rothschild and Miethe (1999)reveals that external whistle blowing only existswhere employees “come to believe that internalchannels are closed to them” and therefore,that the organisation is not open enough.Furthermore, by virtue of the U.S. FederalSentencing Guidelines for Organizations, companieswith adequate procedures for reporting violationsare handed down a reduced sentence whenemployees break the law (Ferrell et al., 1998).The Business Charter for Corporate Citizenship ofthe ICC and the OECD guidelines for multina-tional companies also highlight the importanceof sufficient opportunities for employees toraise incidents without the fear of negative reper-cussions.

The crucial question for ethics managementis therefore, how organisations can create a soundinternal ethics safety net for resolving (or helpingto resolve) undesirable behaviour encountered byemployees which cannot be resolved satisfacto-rily with colleagues and management. In thisregard, fifty-one percent of the thousand largestU.S. companies have an ethics hotline for staffto report incidents anonymously (Weaver et al.,1999), and ten years after it was established in1992, the Ethics Officers Association has 720members from profit and non-profit organisa-tions. At the same time, there are hardly anyethics officers in companies based in other coun-tries (see The Conference Board, 1999; London

Business School, 2000). In the literature, atten-tion is paid to the need for internal whistleblowing procedures and an internal ethics officer(Conference Board, 1999; Ewing, 1977; Ferrelet al., 1998; Gellerman, 1989; Izraeli and BarNir,1998; Kaptein, 1998; Near and Miceli, 1996;Stewart, 1980; Trevinio et al., 1999; Weiss, 1994)and research has been conducted on the func-tioning of ethics officers and ethics hotlines(Ethics Officer Organization, 1997, 2001; Morfet al., 1999; Trevinio et al., 1999). Little hashowever been written about other forms ofinstitutionalising internal ethics safety nets, andscant attention is paid to the methods that areavailable to companies for developing a cus-tomised internal safety net. Where mention ismade of the need for whistle blowing procedures,this is usually followed by the brief advice thatan ethics hotline is desirable, without indicatingwhat the options and decision-making momentsare and how a similar structure can be givenshape.

This article offers guidelines for setting up aninternal ethics safety net, or for improving anexisting one. The design of an ethics safety netdepends on the principles to which the organi-sation wishes to adhere. Subsequently, a numberof factors are discussed that are critical to thedesign of the safety net and where two or moreprinciples are difficult to reconcile. This isfollowed by a discussion of three models that canpotentially be used to create an internallycoherent safety net. The article concludes witha description of one of these models as employedby KPN Telecom. The ethics helpdesk modeloffers a service that complements the usual tasksof the ethics officers as well as a philosophy thatbetter reflects the responsibilities of management,internal departments and employees. This articletherefore, has a message for organisations thatalready have an ethics officer and ethics hotline,as well as those organisations with a differentsafety net model or no safety net at all.

Principles for an internal safety net

To properly organise an ethics safety net, acompany must first identify the principles

220 Muel Kaptein

it wishes to adhere to. The importance thecompany subsequently attaches to each of theseprinciples will determine the set-up of the safetynet. Table III lists nine such principles.

Principle 1: It is the responsibility of the victim orwitness to challenge the perpetrator and to raise theincident with management or support staff when theperpetrator does not respond adequately

In the first instance, it is up to the victim or thewitness to challenge the perpetrator personallyand to resolve the problem if possible. Even ifthe perpetrator does not respond positively, it isup to the victim or witness to go to the linemanager to raise the problem. If this does nothave the desired effect, it is the responsibility ofthe victim or witness to raise the problem withsenior managers or request assistance outside ofthe usual direct channels (see for exampleBovens, 1998).

Principle 2: It is the responsibility of management torecognise incidents and to take care that they areresolved

It is a primary responsibility of the direct linemanager to adequately identify and resolve inci-dents that occur within his department or unit(see Kaptein, 1998). It is therefore particularlyimportant when setting up a safety net, to avoida design where the safety net threatens to replace

management responsibility. “For all your inci-dents go to the safety net”, is not the messagemanagement wants to send to employees. It isnot without reason that a safety net is called asafety net (for the managerial channels). Thereare organisations, therefore, that see the appoint-ment of a counsellor as an interim solution, untilmanagers are deemed adequately equipped toresolve internal departmental problems them-selves. In some instances, organisations alsochoose the option of allowing only managers toconsult the safety net, thus reinforcing theirresponsibilities as much as possible.

Principle 3: It is the responsibility of the support staffto recognise incidents and to see to it that they areresolved

Support staff are there to support managementand to increase efficiency. Support staff havespecific in-house expertise and aim for a uniformway of working within the organisation. As such,the personnel department could have a respon-sibility to deal with misconduct in the workplacethat affects the well-being of employees, the legaldepartment could deal with legal violations, andthe finance department could deal with fraud.And because support staff relationships withemployees are less hierarchical, the threshold forreporting incidents is lower. Moreover, thegreater the responsibility of the support staff, themore independence it will have in deciding howto deal with an issue or incidents.


TABLE IIIPrinciples for the design of an internal ethics safety net

1. It is the responsibility of the witness or victim to challenge the perpetrator and raise the incident when theperpetrator does not respond adequately.

2. It is the responsibility of management to recognise incidents and to see to it that they are resolved.3. It is the responsibility of the support staff to recognise incidents and to see to it that they are resolved.4. Clear structure and procedures for reporting incidents.5. Low threshold for reporting incidents.6. A professional and thorough approach to dealing with incidents.7. Quick and efficient intervention if and when an incident occurs.8. Credibility and integrity of the safety net.9. Organisation-wide opportunities to learn from incidents.

Principle 4: Clear structure and procedures forreporting incidents

It must be clear to all employees which incidentsshould be reported to whom and what thepossible follow-up steps are (ILO, 2000).Questions to which an organisation shouldprovide answers for its employees include:“Which person should be approached for whichincident?”, “Who can be turned to for dilemmas,questions, criticism and complaints?” and “Whatare the different procedures for the different typesof reporting?”.

Principle 5: Low threshold for reporting incidents

In the event that management does not respondadequately to a reported incident, it must bemade as simple as possible for staff to reportunethical conduct outside the hierarchical line ofmanagement. The higher the threshold, the moreincidents that will end up falling to the waysideand the greater the chance of escalation and ofexternal whistle blowing.

Principle 6: A professional and thorough approachto dealing with incidents

Any person who reports an incident shouldreceive professional and proper assistance: fromlistening to the incident being reported to itsinterpretation to deciding on how it should bedealt with to setting up an inquiry and ifappropriate, to drawing the necessary conclusionsand seeing to a follow-up (see also Izraeli andBarNir, 1998). Employees are entitled to a pro-fessional approach and companies have the dutyto offer that (ILO, 2000).

Principle 7: Quick and efficient intervention if andwhen an incident occurs

In most instances, quick action is required toavoid the problem intensifying and to show thatthe problem is being taken seriously (see also theother benefits in Table I). From an efficiencypoint of view, it also makes sense to set up a

safety net as economically as possible (Micelli andNear, 2000).

Principle 8: Credibility and integrity of the safetynet

Conclusions with respect to who the perpetratoris, the extent to which s/he can be blamed andthe measures that have to be taken, should alwaysbe reached in an independent and consistentmanner. The reporting employee must feelassured that the information revealed in confi-dence will be treated with the necessary respectand that “they will not suffer retaliation if theyuse the internal channels” (Near and Miceli,1996). It is lethal for a structure built on trustif employees (victims, witnesses as well as per-petrators) have insufficient confidence in theintegrity of the responsible officers.

Principle 9: Organisation-wide opportunities tolearn from incidents

In order to prevent similar incidents from beingrepeated elsewhere in the organisation, it is ofcrucial importance that the organisation as awhole learns from such incidents. This is essen-tial from the business point of view (to avoidmore costs and trouble), but also from an ethicalperspective. The ethical organisation learns fromincidents by incorporating corrective and pre-ventative activities in its structure and culture(Bovens, 1998; Kaptein, 1998).

Some critical factors

Where there is conflict between two or more ofthe above principles, a choice must be made.Such choices determine the eventual model thatis selected for the ethics safety net. Organisationshave to address these questions in order toproduce a carefully considered layout for theethics safety net. Table IV highlights some criticalfactors that need to be addressed in the designof the ethics safety net and that will be discussedbriefly here.

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Critical factor 1: Avoiding unnecessary reporting oridentifying all incidents?

The higher the threshold, the fewer incidentsthat will be reported to the contact point, thegreater the chance that serious incidents will notbe exposed. However, as the threshold to thecontact point becomes lower, the likelihoodthat it will be used for trivialities (the so-calledvacuum-cleaner effect), increases. All problems,regardless of their validity and seriousnessare absorbed, removing management and staffresponsibilities and creating a lot of work for thecontact point.

Critical factor 2: An internal and/or external contactpoint?

It could be useful especially for smaller organi-sations to have a contact point outside the organ-isation. This can be jointly organised by anumber of companies in the same location,region or sector. According to Trevinio et al.(1999), a number of U.S. companies outsourcetheir telephone hotlines to outside consultanciesor security companies in distant cities. Fifteenpercent of the members of the Ethics OfficersAssociation outsource their internal reportingsystem. Another nineteen percent have a hybrid(internal/outsourced) system (EOA, 2001). Notonly can outsourcing the contact point be less


TABLE IVCritical factors in the design of an internal safety net

Critical factors Conflicting principles

01 Avoiding unnecessary reporting or Efficiency versus effectivenessidentifying all incidents?

02 An internal and/or external contact point? Low thresholds (remains within the organisation) versus low thresholds (anonymity) and credibility (independence)

03 A single service point or one service point Low thresholds (easily accessible) and clear structureper issue? versus efficiency and credibility (no conflict of

interests)04 Centralised and/or decentralised? Efficiency and professionalism versus low thresholds

(contact point within own unit can be more familiar)05 For staff and/or external stakeholders? Efficiency and credibility versus effectiveness and

credibility06 A single officer for all staff or a multitude Efficiency versus effectiveness

of officers?07 Full-time or part-time officer? Professionalism and low thresholds (no possible

interference with other tasks) versus low thresholds(relatively more officers) and efficiency

08 Investigation by manager and/or by Personal line responsibility versus professionalism andinternal department? responsibility of internal department

09 Centralised and/or decentralised registration? Organisation-wide learning versus line responsibility 10 Separate or combined supervising and Credibility versus efficiency

supporting functions? 11 Anonymous reporting or identification? Effectiveness versus employee’s personal responsibility12 Complaints commission or not? Efficiency (flexibility) versus credibility13 Which department does the ethics net Efficiency versus credibility

fall under?14 Reporting only incidents, or dilemmas as well? Personal responsibility of line management and

employees versus low thresholds

expensive for companies, but it can also ensurethat issues are treated professionally and quickly.It is particularly difficult to guarantee confiden-tiality in a smaller company given that everyoneknows each other. An external contact point canserve to instil trust in unprejudiced treatment,confidentiality and anonymity. The potentialdisadvantages of using an external contact pointinclude a lack of insight into the organisation andculture; difficulty in gaining the employees’ con-fidence; and employees interpreting outsourcingas a sign of poor management commitment toethics (see also Trevino et al., 1999).

Critical factor 3: A single service point or oneservice point per issue?

An important advantage of a single service pointis that employees can be easily informed aboutthe structure of the safety net and how to contactit. A single service point can also be cost effec-tive because it avoids duplication. It also offers acentral point from which to get an overview ofall reported incidents. A disadvantage of a singleservice point is the extent to which the corpo-ration’s reputation is dependent on it: if theservice falls into discredit (e.g. due to a singlemisdemeanour) the functioning of the safety netas a whole is threatened. Moreover, a lot ofknowledge and expertise are usually expectedfrom people staffing a single service point. Thereis also the danger that, as fewer people staff thecentral service point, it gets more difficult tomake a distinction between possible conflictingroles. For example, if an incident is reported andneeds to be investigated and the “suspect”requests support in his/her defence at the sametime.

Critical factor 4: Centralised and/or decentralised?

The benefits of a decentralised safety net (i.e. perunit) are employee and manager recognition ofthe local office(r) and the officer’s experiencewith the local culture. Furthermore, it empha-sises the unit management’s responsibility tosupervise the safety net. Employees could doubt

the trustworthiness of a central counsellor andargue that “s/he is not one of ‘us’ but a man-agement stooge”. The more counsellors there arefrom different hierarchical levels (and ethnicbackgrounds and gender), the better the needs ofa diverse staff will be met, consequently loweringthe threshold to reporting. However, the higherthe position of the officer, the more authoritys/he will have with management. Local officersrun the risk of having no access to the board.Moreover, a decentralised position also createsthe risk that the officer concerned gains no expe-rience (because of the proportionally few inci-dents s/he needs to deal with). This leads to asituation where if and when a case arises, theofficer tries too hard to prove the usefulness ofhis/her function that s/he loses sight of the co-responsibility of others in resolving the incident.Like Don Quixote s/he takes up the battleagainst the perpetrator at great risk of beingaccused of fanaticism and not giving adequateconsideration to others’ viewpoints and interests.

Critical factor 5: For staff and/or external stakeholders?

Another question that arises when setting up asafety net is whether the contact point shouldalso be accessible to external stakeholders. Someincidents will be noticed sooner by externalstakeholders (especially if they are the victims)than by employees and managers. Moreover, acontact point for external stakeholders willmake it clear to external stakeholders that theorganisation is serious in its commitment toaddressing and preventing unethical conduct byits employees. In addition, the company may alsolearn valuable lessons from reports from externalstakeholders. A possible disadvantage of makingthe ethics safety net accessible to external peopleis that they may be left with the impression thatthe company is not capable of detecting and pre-venting unethical conduct by itself. Furthermore,a contact point for external stakeholders alsoinvolves higher costs (higher staffing, more com-munication, higher telephone costs with a freenumber, plus more calls from stalkers). A furtherdisadvantage is that a contact point for external

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stakeholders may raise expectations, which, if notmet, may damage the company’s reputation.

Critical factor 6: A single officer for all staff or a multitude of officers?

The greater the number of ethics services andofficers, the more comprehensive the structureand consequently, the more accessible the safetynet. However, the more services there are, thegreater the chance of inadequate coordination.The ideal number of officers will thereforedepend, among other things, on the number ofemployees, the geographical spread of employeesand the nature and scope of the problems.Texaco, for instance, has appointed a complianceofficer per location world wide (50 in total) forreports of violations of its business code. Othercompanies appoint a specialist compliance officerper type of issue company-wide. In this arrange-ment, a separate compliance officer would beappointed for procurement ethics, confidentialinformation and corporate property, etc.

Critical factor 7: Full-time or part-time officer?

The trend in smaller U.S. organisations, from aneconomic point of view, appears to be one ofadding the task of compliance and ethics contactpoint to those of someone within a particulardepartment (EOA, 1997). Of the members of theEthics Officers Association who responded to thesurvey in 2000, fifty-four percent are full-timeethics officers and forty-six percent are part-time(EOA, 2001). When the part-time officer is nota full-time member of the support staff but ispart of the business operations, s/he has theadvantage of remaining involved in practiceand developments on the work floor. Also, thethreshold for such a part-timer is lower becausethe rest of the staff sees him/her as “one of us.”Possible disadvantages are reduced accessibilityand less independence and time constraints dueto other tasks may lead to neglecting officer tasksand responsibilities.

Critical factor 8: Investigation by manager and/or byinternal department?

The model of the ethics safety net that is usedpartly determines whether or not managers cancarry out investigations themselves. Managerswho personally conduct an investigation showthat they take their responsibilities seriously. Suchan approach could also increase the speed ofthe investigation, avoiding perpetuation ofthe incident or escalation of conflict. However,the more complex these investigations get,the greater the chance for an unprofessionalapproach. A manager investigating his/her ownstaff also runs the risk of causing lasting damageto mutual relationships and affecting the trustemployees have in him/her. While employingsupport staff guarantees professionalism, the riskof insufficient insight into the specifics of theincident and adequate involvement of manage-ment in the incident also exists.

Critical factor 9: Centralised and/or decentralised registration?

Central registration of all incidents increasesopportunities for organisational learning. It cancontribute to the timely detection of trends andlinking of incidents. However, registration coststime and money. It is also a question of whatexactly to register and how to safeguard confi-dentiality. Taken to its extreme, a manager wouldhave to centrally register every incident, evenevery suspicion. In many cases the board willinsist that they be promptly informed about atleast the more serious cases of sexual harassment,fraud, gross breaches of internal guidelines, legaltransgressions and violations of external stake-holder rights.

Critical factor 10: Separate or combined functions ofsupporter and investigator?

On the one hand, it is desirable to combine thefunctions of supporter and supervisor, since bothfunctions require the same knowledge. Forexample, officers to whom private trading has


to be reported can simultaneously investigatewhether managers and employees comply withthis regulation. In addition, some questions canlead to better investigations and on the basis ofthe experience gained through such examina-tions, investigators can offer superior answers tothe questions posed. On the other hand, anemployee that presents an officer with a dilemmawith respect to adhering to standards cannot sub-sequently qualify for advance inspection ofhis/her compliance with these same standards.It is also not desirable that the information theemployee makes available to the officer at thetime of his/her enquiry is used against him/herduring inspection. This could lead to a situationwhere someone who is willing to share his or herdilemma stands a better chance of beinginspected than someone who does not. It couldcreate the impression that employees should notask any questions while it is exactly what theorganisation is trying to stimulate.

Critical factor 11: Anonymous reporting or identification?

The option to report incidents anonymouslylowers thresholds. This, however, also increasesthe risk of hoax calls, abusive calls and employeesshedding all responsibility after reporting. More-over, anonymous callers are not available forfurther consultations. Another question is towhat extent can the anonymity of the caller beguaranteed. Sometimes the case may be so inter-twined with the function of the reportingemployee that no matter how much care theofficer takes, s/he cannot avoid relinquishing theidentity of the employee in the process ofaddressing the case. There are organisations thatonly take the matter up with the authorities ifthe reporting party gives permission to do so.Other organisations guarantee in principle theconfidentiality of the reporter’s identity butwould in exceptional circumstances sacrifice theanonymity of the reporter without his or herpermission in order to take measures against theperpetrator.

Critical factor 12: Complaints commission or not?

Sixty-six percent of U.S. companies that have anethics officer also have an ethics commission(EOA, 2001). The presence of an ethics or com-plaints commission can serve the purpose ofemphasising that complaints and dilemmas aretaken seriously and that issues are dealt withobjectively and professionally. The presence ofsuch a commission, however, can also result inassessments becoming slower and less flexibleand in employee reservations about reportingincidents because of doubts in the confidentialityof the commission, especially with a broadrepresentation.

Critical factor 13: Which department does the ethicsnet fall under?

In U.S. companies, twenty-three percent of thecontact points for reporting unethical conductfall under personnel affairs, twenty-three percentunder administration, nineteen percent underlegal affairs, twelve percent under internal auditand eleven percent under finances/accounting(Ethics Officers Association, 1997). The depart-ment the contact point falls under influencesemployees’ perception of the contact point. If itfalls under a department that is more financiallyoriented, the safety net will be seen as a servicefor staff with complaints of primarily financialviolations. If it falls under personnel affairs, it ismore likely to attract reports of social violations.Placing it directly below management canenhance the independence of such a contactpoint. A disadvantage of this is that members ofthe management team may not have enough timeto devote to the supervision of the safety net.

Critical factor 14: Reporting only incidents ordilemmas as well?

Should the safety net be intended for unethicalbehaviour alone or should it also be open to stafffacing a dilemma and requiring advice only? Asafety net exclusively for unethical behaviour willhave far fewer contacts than one that is open to

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questions, problems and dilemmas. Moreover, thebroader the scope of issues that can be raised, themore positive the role of the safety can be. If itonly deals with incidents, the net will be associ-ated with trouble, crisis, guilty parties and costs.

Three models

The choices a company makes with regard to theabove critical factors (on the basis of the princi-ples here described) will determine the structureof the internal safety net. In this regard, roughlythree models can be distinguished for anintegrated and coherent internal safety net: (1)the ethics officer, (2) the ethics co-ordinator and(3) the ethics helpdesk.

In the case of a single safety net there is oneofficer who covers all types of violations.Depending on the choices made with respect tothe critical factors, different variations on thetheme of this single safety net may includecentralised or decentralised officers, internal orexternal officers and, for instance, full-time orpart-time officers. The ethics officer can alsobe indicated with the term “counsellor”, “com-pliance officer”, “integrity officer”, “integritycounsellor” or “ombudsman”. In small compa-nies in particular this should be the favouredmodel. Someone from outside the internal hier-archy is appointed as ethics officer, whom staffcan approach for both social and financial formsof unethical behaviour. The ethics officerdecides, in consultation with the reportingemployee, what the next step should be and whoshould be involved in the issue.

With a composite safety net, there are different

service points for different types of violations. Ifpotential staff issues can be clearly distinguishedand separated from each other, different ethicsservice points can work well alongside eachother. Clear communication about the scope ofthe different service points and coordinationbetween the service points is essential. It is theethics co-ordinator’s task to see to it (behind thescenes) that the scope of the different servicepoints are clear and clearly communicated.

The integrated composite safety net has asingle central service point for all types of vio-lations and from behind which all the officersoperate (whether or not physically). The func-tionaries of the so-called Ethics Helpdesk (or help-line or hotline) decide on the follow-up of areport. The term “helpdesk” is also an invita-tion to staff to approach the service with ques-tions and dilemmas. This name also emphasisestheir personal responsibility in a positive way (thehelp aspect). At the same time, the organisationalso recognises its responsibility (the helpdesk hasthe task of referring staff to the appropriateservice). Staff (and also external stakeholders) can


Figure 1. Model for a single safety net with an ethicsofficer.

Figure 2. Model for a composite safety net with an ethics coordinator.

also approach the officer directly who must thenfeed this back to the helpdesk.

As the ethics officer, the helpdesk can be con-sulted in connection with all forms of unethicalbehaviour. It is the responsibility of the helpdeskto refer the enquirer to the appropriate servicepoint. If there is no service point for a specifictype of issue, the helpdesk has to see to a properfollow-up for the enquirer so that s/he is notleft stranded. This integrated composite approachwill enjoy the preference of large organisationsin particular, where there may be a multitude ofviolations and where often a multitude of servicepoints has sprung up. The difference to themodel with the ethics officer is that the latter ismuch more active during the follow-up and theresolution of the case, whereas the exclusive aimof the helpdesk is to ensure that reports andqueries are properly channelled and referred. Incontrast, the ethics officer has much greaterpersonal authority to initiate investigations, etc.(see Table V for the differences).

The ethics helpdesk works as follows:

1. Intake. The caller (internal and possiblyalso an external stakeholder) is offered asounding board for discussing a complaint,dilemma or question. The points for atten-tion during this phase include gaininginsight into the specific case, listening to thefeelings of the caller, building trust andexplaining the procedures and possibilitiesoffered by the Ethics Helpdesk. Thehelpdesk worker is, however, not personallyresponsible for the subsequent counsellingand compliance tasks.

2. Registration. The helpdesk worker registersthe details of the call in the system.

3. Referral. On the basis of a rough descriptionof the report, it is determined who theappropriate officer in the organisation is tofollow up the request. For this purpose, thehelpdesk worker needs to have an ethicssafety net map of the organisation that indi-cates the appropriate member of staff for aparticular issue.

4. Follow-up. In consultation with the caller,the helpdesk worker then makes anappointment for the follow-up support: bywhom and when, for instance, contactwill be made. It is the helpdesk worker’sresponsibility to ensure that contact is madebetween the caller and the appropriateofficer. The helpdesk also keeps track ofthe follow-up process. The officers arealso responsible for the registration by thehelpdesk of requests made directly tothem. The helpdesk regularly reports tomanagement.

Different roles in the safety net

Due to the different roles within a safety net, itis sensible to think about which service takes onwhich role. Table V shows the possible roles ofthe different services. As demonstrated byTable V, the ethics officer can take on a varietyof roles. The risk in this respect is that thereliability and effectiveness of the safety net maybe jeopardised. The table also clearly shows theimportance of the role of line management in the

228 Muel Kaptein

Figure 3. Model for an integrated composite safety net with an ethics helpdesk.

ethics safety net. The next section describes theKPN Telecom safety net as illustration of thehelpdesk model.

KPN Helpdesk Security and Integrity

KPN Telecom is a company that offers a widerange of telecommunication services. With38,500 employees in the summer of 2001, it isone of the top five European telecom companies.The company is listed on the Amsterdam, NewYork, London and Frankfurt stock exchanges.Following a preparation period spanning morethan two years, KPN introduced a company codeof conduct in October 2000. The code ofconduct, comprising 2100 words and entitledWhat Unites Us, applies to the entire staff. Thecode describes the ambitions and responsibilitiesrecognised by the company per stakeholder(clients, financiers, staff, business partners, com-petitors, environment, society and legislators,both domestic and international). The code alsodefines the rules of conduct for employeesregarding, for example, confidential information,

interpersonal behaviour, corporate assets and IT-means. The Board of Directors decided that forstaff and external stakeholders to see the code asa credible ambition, the company should havea comprehensive and sound safety net beforepublishing the code. With the safety net, theboard wants to send a clear message that there isa sounding board for the problems of employeesand that many forms of misconduct are notprivate, but corporate issues. After extensive dis-cussions, the decision was made in favour of theethics helpdesk model.

Scope

The KPN code of conduct refers extensively tothe helpdesk. “KPN employees may encounterproblems, incidents and questions related toobserving the code. If these problems cannot beresolved by the line organisation and/or with thepersons directly involved, employees may contactthe KPN Security & Integrity Helpdesk,” thecode states. Possible issues with which staff mayapproach the helpdesk can vary from leaking


TABLE VRoles in the safety net

Different roles in the safety net EO EC HD CL CO ECM IRB SS LM

01 Contact/information point X X X X X X X X02 Coach X X03 Referrer X X X X X X X04 Intermediary X X X X05 Endorser X X X X06 Investigator X X X X X X07 Supporter in defence X X08 Adviser on measures/sanctions X X X X X09 Registrar X X X X X X X X10 Policy adviser X X X X X X X X X11 Booster X X X X X X X12 Follow-up care X X X13 Supervisor X X X X X X X X14 Norm-setter X15 Decision-maker on Sanctions X16 Controller X X

EO = Ethics officer, EC = Ethics coordinator, HD = Helpdesk, CL = Counsellor, CO = Compliance officer,ECM = Ethics commission, IRB = Internal Review Board, SS = Support staff, LM = Line management.

confidential information, unauthorised use ofpasswords, conflict of interests, bullying, sexualintimidation and, for instance, harm to stake-holders like consumers and suppliers. Thehelpdesk is also available for questions anddilemmas relating to, for example, insider knowl-edge, purchasing, personal behaviour, culturaldifferences, sideline activities and the use ofcompany resources for private purposes.Managers can also contact the helpdesk forsupport in resolving integrity issues in theirdepartments or units. The contact point is for theexclusive use of staff, and not for external stake-holders because such an expansion would besignificantly more complex and experience is firstneeded to be gained with the current set-up.Moreover, in the context of the implementationof the code, stakeholder-owners were appointedwho are chiefly responsible for communicatingwith the relevant stakeholders and finding outabout incidents and issues stakeholders are con-cerned about.

Accessibility, staffing and working method

All employees have access to the Security andIntegrity Helpdesk that can be reached via a freephone number, 24 hours per day, seven days perweek. Since January 2001, the helpdesk hasemployed eight staff members and a manager.The helpdesk is chiefly centrally financed so asto emphasise its importance to the organisationas a whole. Rates for research activities have beenpre-established and are charged to the subdivi-sions without exception. The functions that arepart of the helpdesk service are explicitly definedand set out in a protocol. The helpdesk workerfunctions as first point of contact and support forpeople with a complaint relating to compliancewith or interpretation of the code. The helpdeskworker has the additional tasks of referring thecaller through and monitoring the process. Thehelpdesk worker supports the caller and offershim or her a sounding board. Once the natureof the problem has been identified, follow-upappointments are made. Normally, the helpdeskworker would refer the caller to the appropriateofficer within KPN. The helpdesk worker also

registers the call in the system. Because therearguard also registers their actions in thesystem, the helpdesk worker can monitorprogress and, if required, urge the rearguard toact with more speed. The helpdesk worker alsoacts as a filter to avoid as far as possible trivialissues receiving the full treatment. Helpdeskworkers also have the specific task of stipulatingthe caller’s responsibilities in resolving theincident internally. In order to make the calleraware of his/her personal and functional respon-sibilities and to prevent abusive calls, anonymouscalls are not accepted. It is only when the issueis of a sufficiently serious nature, supported byhard evidence, and the caller has credible groundsfor wishing not to be identified that the helpdeskmay decide to take action on the basis of ananonymous call.

Rearguard

The rearguard includes counsellors who arefamiliar with each organisational unit and whodeal with unacceptable interpersonal behaviour,integrity investigators who investigate incidentsand compliance officers who supervise the adher-ence to internal and external rules. The integrityinvestigators carry out investigations where theline organisation is possibly also involved in theincident and/or if specific expertise is required.It is usually up to the managers to decidewhether to carry out an investigation personallyor to involve the integrity investigators. KPN hasseparate compliance officers, among others forprivacy, insider knowledge, company resources,purchasing and IT. Employees can also directlyapproach the counsellor in the department orunit or the relevant compliance officer. In thatevent, the rearguard officer in question will seeto the (initial) support of the caller. The infor-mation to be registered is submitted and enteredaccording to the agreed standard procedures andis forwarded to the helpdesk. While the imple-mented model has one central service point (thehelpdesk), the individual service points alsoremain directly accessible (except for the com-plaints commission, which can only be accessedvia the line). Figure 4 contains a schematic

230 Muel Kaptein

representation of the structure of the safety netof KPN.

At least once a year, all employees involvedin the ethics safety net get together to shareexperiences and discuss bottlenecks. When thehelpdesk was set up, the safety net staff memberswere instructed in the structure and functioningof the helpdesk and received training in dealingwith reports properly.

Confidentiality

An important prerequisite for the effectiveness ofa safety net is the level of confidentiality withwhich information is treated. All helpdesk andrearguard staff emphasise to their callers the con-fidentiality of conversations. It is up to the callerto decide whether to surrender his or heranonymity and, for example, to submit an officialcomplaint against a perpetrator. In all cases wherethe caller reports inappropriate behaviour of

which s/he is the victim, s/he retains the rightto withdraw the complaint. The helpdeskworkers also fulfil no other function inside theorganisation. Moreover, both technical andorganisational measures have been taken to guar-antee confidentiality as far as possible and toprevent loss, theft or unauthorised use of infor-mation. In this regard, the registration system islocated on a separate server that is accessible onlyvia the KPN intranet to authorised KPN staffwhose tasks require them to have access. Thesame applies to physical access to the helpdesk.The KPN staff concerned are all screened andbound by a duty of confidentiality.

Communication

Within KPN, existence and functioning ofthe helpdesk are communicated to employees indifferent ways. In the first instance, the helpdeskis clearly mentioned in the KPN code of conduct


Figure 4. Ethics safety net of KPN.

that each KPN member of staff has to complywith. In addition, brochures and fact sheetswith information, rules and guidelines aboutthe helpdesk are available and can be requestedby any KPN employee. All employees carry apersonal identification card with the number ofthe helpdesk on it. Finally, detailed and up-to-date information is available via the KPNIntranet.

Reporting

The head of security reports to the chair of theBoard of Directors as well as to the managementof the different business units. The latter takesplace on a regular basis (at least once a month)and concerns the nature and scope of requestsreceived via the helpdesk. Three full-timeanalysts prepare the relevant reports in line withthe structure of the code of conduct. They areresponsible for analysing the registered data andtranslating this into adequate management infor-mation (in terms of the seriousness of theproblem, its causes, the relationship between dif-ferent reports, weaknesses in the organisation,prevention strategies). On this basis, managementcan take concrete steps for improvement. Asimilar evaluation enables management sensitivityto the correct implementation of the KPN codeof conduct and hopefully contributes to depart-mental discussions on improving implementation.When KPN prepares external reports on com-pliance with the code of conduct, the informa-tion generated by the helpdesk will also beincluded.

Effectiveness

In the first year after the introduction of thehelpdesk, approximately 800 to 900 reports wereregistered by the helpdesk per quarter, which inturn resulted in about 200 to 300 investigationsper quarter. A large number of reports relate tomisuse of property and theft. A survey that wascirculated among staff a year after the helpdesk’sinception, shows that most employees are awareof the existence of the safety net and that they

have sufficient confidence that there is roomwithin the organisation for addressing incidents.In the same period, the audit department carriedout an investigation of the performance of thehelpdesk itself. The systems and proceduresappeared to withstand the test, but the activitiesand benefits of the helpdesk needed to be moreeffectively communicated. These first signs ofsuccess can be accounted for particularly by thefact that the helpdesk forms part of a widerbusiness philosophy with a positive underlyingtone. The rearguard too, is enthusiastic about thehelpdesk structure because their tasks are wellcoordinated not only among each other, but alsowithin the organisation. It is especially importantthat the head of the helpdesk remains alert to thecollapse of the safety net.

Conclusion

The model chosen by KPN is characterised byits easy accessibility and a simple reporting struc-ture. Blind spots are avoided because the helpdeskhas the responsibility of pointing callers in theright direction. Helpdesk workers cannot turnemployees away with the excuse that they cannothelp them. Good coordination between coun-sellors, compliance officers and company securityis necessary for the helpdesk to function properly.The central helpdesk design facilitates adequatesupervision and reporting. At the same time, thehelpdesk is not a contact point where staffcan simply raise issues without any further ado.The helpdesk philosophy emphasises employees’personal responsibility in finding a solution to theproblem (as opposed to the helpdesk simplytaking over the issues and problems). The pref-erence for a broad set-up also makes positiveinput possible. The helpdesk does not only servethe interests of the company, but also those ofthe employees. The helpdesk functions as outletfor staff confronted with dilemmas, thus institu-tionalising openness around the line organisationwithout undermining openness within the lineorganisation and the work processes. In thisrespect, the integrity approach and the compli-ance approach (Paine, 1994) are integrated:internal organisational openness and personal

232 Muel Kaptein

responsibility of staff are stimulated, in turnlinked with monitoring and compliance to thecode. In addition to the informed decision KPNmade with respect to the critical factors describedin this article, the implementation of the safetynet also meets a number of crucial criteria. Theseinclude management commitment, correspon-dence with the code of conduct, clearly definedprocedures for the functioning of the safety net,training for the people involved, communicationand awareness-raising activities aimed at staff,regular reporting and regular effectiveness assess-ments of the safety net itself.

Organisations often have a starting point forimproving their ethics safety net. Organisationsthat have delegated ethics policy to a givenemployee could start with a review of the ethicsservice points and identify blind spots. A similarcoordinator would be wise to get all the repre-sentatives of the different service points aroundone table (the second model). Organisations thatalready have a counsellor or compliance officercould determine to what extent the range ofduties could be expanded (the first model).Perhaps the security department could be mademore visible as a contact point. Organisations thatalready have an established complaints or infor-mation helpline for external stakeholders couldconsider opening this up to staff (third model).And that brings us back to the purpose of thisarticle: offering companies tools for assessing thequality of their present safety nets and improvingthem where necessary.

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Business-Society Management,F4-64,

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P.O. Box 1738,3000 DR Rotterdam,

The NetherlandsE-mail: [email protected]

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Guidelines for the Development of an Ethics Safety Net

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