Responding to Whistleblowers: A Structured Triage Program is Essential

As corporations continue to adopt whistleblower programs, many find themselves struggling to manage burgeoning caseloads. Organizations can minimize regulatory risks by implementing a timely, systematic, and repeatable process for evaluating and prioritizing whistleblower tips. While there is no single, right method for following up on complaints, the most effective approaches to handling these cases often resemble the medical triage programs that hospitals and first responders use to allocate limited resources during emergencies.

Under a fraud triage program, the same principles apply. Hotline tips or complaints that do not indicate fraudulent behavior can be delegated to human resources, IT, or other line or support functions that are capable of handling them more efficiently. Meanwhile, complaints that involve suspected fraud, but which are less significant in terms of financial losses, control failures or other risks, may be set aside temporarily while larger, more material cases receive immediate attention. 

Whistleblower triage stages

 

Despite extensive corporate fraud detection measures in place, including closer management scrutiny, and the use of increasingly sophisticated technology, the most common fraud detection method is still the simplest: somebody notices something suspicious and decides to speak up.

Jonathan Marks

Managing Director

Navigant

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