A whistleblowing case study from Air Liquide : a French multinational company which supplies gases, technologies and services to various industrial and healthcare activities.
The businesses headquarters are in Paris, and it employs around 64,000 people in over 80 countries, servicing 3.7 million customers.
Air Liquide has been a Safecall client since 2015. Here Vincent Maret, Group Ethics Office, explains how he and his team deliver such a far reaching programme.
What prompted Air Liquide’s compliance and whistleblowing policy?
We were relatively early in our focus on ethics and compliance. Our Board is very engaged with the topic which has ensured we were able to act swiftly in developing our offering in this space. We have a dedicated compliance programme with one of the pillars being Ethicall, the name we use for our whistleblowing service.
When we started working with Safecall in 2015 there was no obligation for us to have a whistleblowing line. However, the team saw that a whistleblowing hotline would enrich our compliance programme Sure enough, by late 2016 Sapin II was established in France. This compliance regulation is designed to support anti-corruption and bribery behavior in large corporations and applies to any organisation with more than 500 employees or 100m+ Euros in sales.
It has eight different pillars, one of these is a whistleblowing system. This particular requirement is now applied to any organisation with more than 50 employees and should be available to staff and third-party suppliers.
Why did you choose Safecall as your provider?
The Sapin II Regulation states that the whistleblowing hotline can be provided internally or externally, but given the number of employees that can use this and the various languages to manage, we felt external was more suitable. There are a number of reasons we chose Safecall, one being that it was in Europe which was an important factor in terms of data privacy. [1]
We also wanted a tool that allowed people to raise a report both online and via telephone. We prefer reports that are made via telephone as, thanks to Safecall’s experienced call handlers, they provide more detail and chance to feedback to the caller. Safecall’s focus on professional call handlers with investigative experience who do not use a script and really engage with callers, thereby maximizing the insight gained for each report, was a huge selling point for us.
You operate in over 80 countries, do you notice how different cultures impact the attitude towards compliance and whistleblowing?
Culture varies greatly from one country to another. When we began using Safecall in 2015 the concept was already very developed in the US and Brazil, far less so in Europe. In particular Latin countries were not good contributors, perhaps with the exception of France. Over the next three years credibility of the hotline grew and we now have the expected level of reports from around 40 of our 80 locations.
Do you have an awareness campaign around the programme?
When we implemented the system we had many specific awareness sessions and presentations. Every year we review our Code of Conduct e-learning module which includes information about the programme.
We also have an ongoing communications campaign located at hot spots in each location, such as the coffee machine, where people can easily see details with a summary of the system and process to make a report, and of course we have an Intranet with all the information available. It is really almost impossible for an employee not to know about Ethicall, and Safecall by now. For third-parties we have plans to develop more thorough communications. It is on our agenda for this year.
What actions did you take to develop confidence in the programme and hotline?
The trust for the system was not there at the beginning. In order to instill confidence we try to make change within the organisation very visible. As a result people started to see that when a report was raised change did happen and no repercussions were faced by the person who reported it. That drove the credibility of the system.
For those that make a report we think that it is beneficial for them to see action being taken once they make the call. We therefore have a commitment to close every case in less than 2 months and we track cases not closed within this time period. Our Board is very engaged with the programme and this sets the tone for the business and has proved beneficial in employee buy-in.
What are your future plans around compliance and whistleblowing?
As mentioned we are working on our communications to third parties. We are also looking at how to drive quality over quantity from reports. We want people to feel comfortable speaking up so the messaging must be carefully thought out. Currently we consider about 30% of our reports to be substantiated following our enquiries. We would prefer this to be around 70%. By that I mean that we want to focus on reports being genuine violations and not organizational matters such as salary complaints. We therefore need to work on how we explain this to staff without making them unsure of whether to use the hotline.
We are also looking at our investigations around reports. When a report is made via telephone we get a high level of detail thanks to Safecall’s call handlers. It makes it far easier to look into matters than when a report is made online. We are working with Safecall to develop our internal investigation skills to ensure that our internal team is able to do a thorough job or that we can bring in an external investigator such as Safecall.
With upcoming developments such as the EU Whistleblowing Directive we are also making sure that our policies are compliant. For example, we already ensured data confidentiality as, once an alert is closed as non-substantive, we have a two month delay before making it anonymous and erasing personal data. Safecall’s tool allows us to do this and supports other compliance processes that may become regulated, this is another reason we have remained a Safecall client.
Footnotes
[1] Whilst Safecall is based in the UK, and no longer a part of the EU, it adheres stringently to the GDPR and is able to provide clients with assurance that data protection is by design and not simply by chance.