We are approaching the deadline for transposition of the European directive 2019/1937 for the protection of the whistleblower of December 2021 and, among other things, companies with more than 50 employees must gradually implement their complaints channel. As the directive says, it will be a key and mandatory piece to have an internal complaints channel. Clients ask us for complaint channel models.
Many organizations are currently rushing for implementation, we have prepared some ideas to define a channel framework model for organizations.
We will talk about a complaints channel, due to its translation into the European directive. Other equivalent meanings of the reporting channel could be: ethical channel, compliance channel, irregularity channel or alert channel, among others. By similarity to the directive, we speak of a complaint channel.
Complaints channel model. Framework.
- Define the channel policy
- Channel scope / scope
- Typology of irregularities managed
- Channel management processes
- Who manages the channel and associated investigations
- Negotiation / consultation with worker representatives
- Canal implantation
- Configure client image
- Adapt to defined policy
- Validate protocols
- Communication and dissemination
- Communicate the existence and scope of the channel to the organization
- Communication plan
- Employee Manual
- New contracts
- Regular awareness-raising communications
- To the channel managers
- To channel users, adapted to the different profiles of the organization
- Channel monitoring and supervision
Examples of complaints channel policies.
Examples are often helpful or inspiring. In this sense, as the policies of ethical channels or complaints are usually public, we have made a small compilation as a reference of examples of complaint channels that serve as inspiration in a complaints channel model.
- REPSOL Repsol Code of Ethics and Conduct
- ACS Ethical Channel Operation Policy
- ISGLOBAL Foundation Protocol for the Management, Investigation and External Response of Complaints
- Grupo Azcoyen POLICY OF THE COMPLAINT CHANNEL – Grupo Azkoyen
- CaixaBank Code of Ethics and Business Principles – CaixaBank
- Cepsa ETHICS AND COMPLIANCE CHANNEL POLICY – Cepsa
- Indra Code of Ethics and Legal Compliance – Indra
Regarding the technological tool that supports the process, there are still many organizations that use an email or an internal form on the web. In most cases, two mandatory principles, confidentiality and anonymity, are not met.
ithikios is a whistleblower / ethical channel designed with users in mind and facilitating everyone’s work. Super simple to use and configure and very easy to learn. If you want to see it ask us for a demo, or if you prefer to try it yourself, you can also request a trial .