The Sarbanes-Oxley Act requires publicly held (traded on stock exchanges) companies to have a confidential, anonymous system for reporting concerns. While the ultimate goal of this requirement is that critical information will reach the company’s audit committee, audit committees frequently rely on company staff to process complaints that might come through a hotline, and so anonymous hotline complaints tend to go to the head of Human Resources; if that is the person about whom you wish to file a complaint, this system might not be right for you. Companies sometimes recognize this type of conflict can arise and hire an independent company to handle that hotline. Such hotlines may be staffed 24/7; alternately, the caller may get a voicemail box.
How can you find a company’s anonymous hotline? This is far more challenging today than it needs to be. You can certainly start by going to Google and entering the company’s name and the words “anonymous hotline.” Alternately, Google the company's name and the phrase "Code of Conduct;' sometimes, the Code of Conduct will reference anonymous reporting of ethical concerns. Unfortunately, we’ve learned that companies today make searching for their anonymous hotlines staggeringly difficult by:
- employing imaginative names for their hotlines,
- burying information about their hotlines in PDFs, and
- then, when describing their hotline, failing to actually list the number.
Examples of terms we've seen in a cursory search so far include:
- AlertLine ®
- SpeakUp Hotline
- Ethics Line
- Employee Complaint Line
- Integrity Hotline
- Integrity Helpline
- Business Conduct Helpline
Variations you might then try would include "line," "helpline" and potentially "confidential." If you get nowhere with this, it might be helpful to search for the company name and "Code of Conduct."
With an appropriately administered hotline, the experience you report will be given a report number so that you can call back and inquire about whether an investigation has started and what its conclusions are.