How should reports be processed?

You are free to deal with the information as per your policies if any or in such manner as you may deem appropriate. You have the option of seeking additional information from the reporter if you so require and keep him informed about the progress if you so desire. It is advised that all reports be taken to their logical conclusion and closed within a period of six months of their receipt. It is desirable that all verifiable and actionable facts disclosed in a report be cross checked before commencing any proceeding.

Processing of Information

Taking any piece of information to its logical conclusion envisages, in some combination or the other, the activities of sorting, developing, enquiring and acting on the same. Each of these is an important function and requires specialized skills and expertise to ensure that neither do you miss out on anything of relevance nor do you end up raising an alarm when none is required.
Sorting and Smart Vigilance
While sorting and processing reports please remember that the raison’d’tre for a robust vigilance mechanism is not to reduce but to increase the level of efficiency and effectiveness in an organization. Smart Vigilance requires you to remain vigilant and yet not interfere or obstruct the functioning of the other departments in your organization. It envisages dealing with information objectively and on merits without any fraternal sympathy, bias, prejudice or affectations.
Proactive Vigilance
Proactive vigilance starts from the assumption that commercial risk taking forms a part of business and therefore many a times ‘out of the box’ actions and decisions which on their face appear to be ‘out of sync’ may in fact be in organizational interest. Thus every loss to the organization-pecuniary or otherwise, every allegation or suggestion-personal or otherwise and every decision whether in consonance with organizational policy or otherwise may not necessarily be a subject matter of scrutiny. Though there can be no strait jacket rules in this evaluation yet the test of a reasonable man i.e “whether a person of common prudence would have acted in a similar manner in the prevailing circumstances in the best commercial and operational interests of the organization” can be considered  as one  possible criterion for ascertaining the bonafides of an action. What should be scrutinized and to what extent and what should be ignored is a  reasoned and calculated decision which needs to be taken depending upon the facts and circumstances of each case and organization. More often than not while dealing with information and assessing how to process it  you may just be required to act as a sponge and absorb it rather than act on or react to it.
Developing Information
The information that you receive may not necessarily be in a form which may be useful to you. In such a situation you would be required to interact with the whistleblower to develop the information further. The kind of queries and responses that need to be posted to reassure a whistleblower and elicit  verifiable and actionable facts from him requires patience and a non adversarial approach bereft of any preconceived notions. Irrespective of the content of a report it is imperative that some suitable response is posted within 24 hours of the receipt of a report so that the whistleblower knows that his concern has been noted by someone responsive at the other end. More often than not sustained interaction over a period of time may be required before one can gather information that merits investigation. During this interaction no response ought to be posted which purports to seek such information which the reporter is not comfortable disclosing or which is intimidatory or threatening in nature. A sine qua non for ensuring free and fair reporting de hors any prior prejudice is that you should not disclose your identity and refrain from demonstrating any familiarity or affectation in any response posted by you. It is imperative that all communication is strictly formal and only on a need to do and need to know basis. Remember that people will disclose facts only if you ask them the right questions at the right time. They will talk to you only if they trust you and have the confidence that you will take them seriously.You must view the reporter as an ally and not as an adversary.
Enquiry: Scope and Manner
Having received the information, converted it into a form suitable for an enquiry you will now be required to decide on its scope and the mode and manner in which it is to be conducted. As a general rule it is always advisable that the initial scope of enquiry be limited to the verification of facts using the principle of least inconvenience, obstruction and exposure. Since the outcome of a preliminary enquiry may or may not lead to anything substantive therefore it is desirable that it be conducted in a very discreet manner lest it impair the smooth functioning of the organization and adversely effect staff morale and efficiency. During this process extra care must be taken to ensure that no act of the enquiry officer compromises the position of the whistleblower in any manner whatsoever. For example if in response to a report an enquiry officer immediately summons the concerned Department Head or seeks the  records/details pertaining to a specific concern which is the subject matter of the report then despite his best intentions he increases the chances of exposing the whistleblower for he may be someone who is/was dealing with the matter and had raised the concern internally without success.
Action Call after Enquiry  
Once the preliminary enquiry is complete you will need to take a call on the future course of action. This decision is vital in as much as it may end up setting benchmarks within the system thereby effecting organizational behaviour. Not every enquiry may warrant further action and not every aberration may warrant the strictest possible action. Yet in appropriate cases such appropriate and proportionate action ought to be taken as may be necessary to prevent recurrence and safeguard organizational interest.
Anonymous Reports
Additionally while dealing with anonymous reports remember that there is nothing which prevents you from reading the same and suo moto subjecting them to such preliminary scrutiny or verification as you may deem fit to prima facie test the veracity of the allegations before proceeding any further.
We call the process right from the receipt of information to the preparation of the action taken report as Disclosure Management. We can stay with you throughout the information lifecycle and help you deal with it effectively and appropriately while you focus on your core area of business.
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