Multi-Industry Ethics

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  • 1.  Escalation Policies

    Posted 4 days ago

    Our executive team is looking to develop a protocol for escalating certain compliance and HR issues to their attention (and possibly to others in the org as well). 

    I'm interested in learning what other companies have developed in this regard. Again, my focus is on escalation of compliance and HR issues. For example:

     

    • Bribery
    • Sexual assault
    • Violence resulting in injury/death
    • Misconduct by senior managers
    • Criminal matters

     

    If you have a protocol, I'm also interested in when you escalate and to whom (senior management, Board, etc.) 

    Many thanks,



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    Toks Joseph
    VP Global Compliance & Ethics
    Cargill
    Darnestown,MD
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    SCCE Membership


  • 2.  RE: Escalation Policies

    Posted 4 days ago
    I would always require escalation of any allegation revolving senior management, including the CEO, to the board.  I would leave no wiggle room. However, this can be much easier than it sounds.  Simply an email to the chair of the audit committee would be enough.  If the allegation is really off base, trust the intelligence of the audit committee chair to make that judgement.  But never, ever leave it to management discretion when it comes to serious allegations and especially about senior managers. Never require that it be "material" - that is an open invitation to rationalization.  It is just way too easy to justify not reporting something, especially when it involves the top bosses (i.e., the C-suite). Determine in advance what is important (e.g., any allegation involving the c-suite), then let the audit committee chair decide if any particular report or case is really important enough to require board level follow-up.  Cheers, Joe   



    SCCE Membership