Breach reporting mechanisms

20 february, 2023

The introduction of reporting processes in the company is one of the biggest challenges for implementing compliance policies. Companies that have declared their values of transparency and accountability have to communicate consistently with both employees and counterparties and are expected to provide accessible mechanisms for reporting violations.

We would like to pay attention to the three key procedures.

1. Setting up an internal mechanism for reporting violations.

The mechanism for reporting violations is considered the most optimal if it includes:

  •  hotline: available in various formats (phone number, e-mail, message box, application, form on the website); is confidential and/or anonymous; available not only to employees but also to contractors;
  • employees and contractors are aware of the possibility of its use and are encouraged to do so in case of any violations;
  • the history of appeals and appropriate responses is kept.

2. Introduction of whistleblower rights protection tools.
The whistleblower must ensure confidentiality and anonymity, receive information about the consideration of the information provided by the whistleblower, and be protected from harassment and pressure.
3. Development of the procedure for conducting internal investigations.
Such a procedure should regulate the grounds for conducting internal investigations, involved persons, time limits, options for actions based on the results of the investigation, as well as issues of access to personal data.

What problems has your company faced in the field of reporting violations?

 Detailed instructions for business "Basic principles of risk identification and their minimization" at the link: