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There is a significantly pronounced emphasis on introduction of the Whistleblower Policy and Scheme at both the corporate sector as well as the public sector organizations. Executive Management is charged with the responsibility of safeguarding the organization from the potential damages inflicted by occurrence of unfair and unethical business practices across the organization as well as for smooth corporate governance. The potential damages may result in any one or more of the following:

	Substantial Financial Loss: According to the ‘2012 Report to Nations on Occupational Fraud and Abuse’ by the Association of Chartered Fraud Examiners, an average organization loses 5% of its revenue annually on account of Fraud. This study was based on analysis of 1388 cases from 100 countries across the world.
	Loss of Goodwill and Reputation: Lehman Brothers, Barings, Enron, HSBC Bank, Barclays, Adidas, etc. lost their reputation and goodwill built over years on account of unethical and fraudulent acts of a few employees whilst the other employees chose to be mute spectators instead of blowing whistle on the wrong doers.
	Penal Action against the Executive Management: There have been several cases where executive management have been penalised for actions of the employees.
The incidents of occurrence of such unfair business practices can be detected only through collaborative vigilance by all employees. The Whistleblower System (Speak-up) provides means for the desired collective vigilance. For confidential reporting of the unethical practices, the Speak-up scheme provides a confidential and secure channel of communication between the ‘whistleblowers’ and the executive management. A Well implemented “Speak up System” helps the Executive Management in:
	Preventing consequential Penal action
	Safeguarding the organization against:
	> Potential Financial Leakages, and > Loss of Good Will
	Meeting with statutory obligations

The “Whistleblower system” (Speak-up) is traditionally implemented in the following manner:

	The Whistleblower Policy and its implementation scheme with its associated rules are announced by the management.
	A hotline telephone number is provided to the employees to report the Whistleblower complaint. This hotline may be manned by a service provider, or by a senior designated executive of the company (generally a CXX level person). The speak-up so received would then be put through the speak-up process by the receiver. Or/and
	An email address is provided to the employees to email the speak-up. On receipt the speak-up email is processed as above. Or/and
	The “speak-up” boxes together with the pre-printed stationary are placed at prominent locations within the organization. A contributing employee is expected to write the speak-up and drop in a speak-up box. Authorised persons open the speak-up boxes at the defined frequency (usually monthly) and process the speak-ups as per the announced scheme. Or/and
	Company’s portal wherein an employee can lodge the speak-up for further processing.

Usually the following barriers are encountered.

	Fear of Reprisal: The biggest deterrent to the success and effectiveness of the ‘Whistleblower Policy and Scheme’ is the fear of reprisal through victimization. This is because the employees are not sure whether anonymity of the whistleblower would be ensured as well as confidentiality of the speak-up maintained, both in a fool proof manner, and hence would rather be mute spectators than jeopardizing their career and at times even bodily safety.
	Fear of a Social Stigma: An employee afraid of being labeled by colleagues, a “Snitch” who instead of focusing on his/her work pokes its nose into others’ affaires to toady the management.
	Delay in Processing: Processing of the speak-ups takes a long time. This is so because there is no automated work flow built in the process to arrest delays at every step of the process.
	Lack of Communication from Management: The whistleblower is not kept informed of the speak-up’s progress and actions taken if any. It is more so for the anonymous speak-ups.
	Absence of a Reward Scheme: Reward scheme for the speak-up scheme is usually not in place or is not administered promptly. Absence of an adequately suitable or a delayed reward may discourage an employee from taking the risk of blowing whistle.
The above barriers result in lack of participation by the employees in the speak-up scheme.

	“iSuggestNow” being a cloud based system allows an employee to enter a speak-up anytime from anywhere through an internet enabled PC or a laptop. The supporting documents can be scanned and uploaded as attachments to the speak-up. In the speak-up the employee has the option to opt for anonymity.
	On successful submission, the employee would receive a unique reference number allotted to the speak-up.
	The system will forward the speak-up with all details to the scheme administrator together with an email alert. The scheme administrator will examine the speak-up w.r.t. the whistleblower policy. If a speak-up fails this scrutiny, the administrator may reject the speak-up which will trigger an automatic email sent to the whistleblower by the system informing of the rejection of the speak-up and reasons thereof. A speak-up that is compliant with the policy would be forwarded for investigation to the assigned Assessor and an email sent by the system automatically to the assessor (investigator) as well as the whistleblower advising of the action.
	The Assessor would carry out investigation. In case any clarification is required from the whistleblower, the Assessor would enter the query in the speak-up form on the screen and without knowing the email address, instruct the system to electronically forward the query to the whistleblower. The whistleblower on receipt of the message would enter the clarifications and (without knowing the Assessor’s identity) reply through the system to the Assessor. On completion of investigation, the Assessor would enter the findings and recommendations, upload scanned copies of any supporting documents and instruct the system to electronically forward to the lead assessor (approving authority) with a notification email, as well as send an email to the whistleblower advising progress. As explained above, the system provides a facility to both the assessor as well as the lead assessor to communicate with the whistleblower for obtaining clarifications. This facility is provided even if the speak-up is marked anonymous.
	The Lead Assessor (approving authority) would take a decision on the speak-up and either reject it or institute appropriate further actions. In both cases the system will send an email to the whistleblower advising the outcome
	Any delay beyond the expected time frame (norms) for any step of the process would result in an automatic alert email being sent to the owner of the step & the scheme administrator. In case of further delay beyond the specified number of days, the matter will be escalated by automatically sending an appropriate email to the designated higher level manager and the scheme administrator with copy to the Assessor.
	Dashboard and other analytics provided in the system would enable analysis of the speak-ups received from various perspectives thereby making it easy to do reporting of the speak-ups’ status to the management. Senior management may view the dash board and take proper consequent actions.
	The whistleblower may view status of a speak-up at any time. The whistleblower may also view the comments and remarks by the Administrator, Assessor and Lead Assessor (if this option has been chosen while configuring the system) entered while processing the speak-up.
	To motivate participation, an ingenious reward scheme has also been built in the iSuggestNow system. Reward points may be awarded to the whistleblower in two stages: first on administrator finding a speak-up to be within the whistleblower policy guidelines and worthy of assessment (e.g. 20 points) and/or on final approval by the lead assessor (e.g. 100 points). The reward points would be automatically credited to the account of the whistleblower maintained by the iSuggestNow system. The company can decide monetary value of each reward point that will be displayed in the whistleblowers account. The whistleblower can redeem the points himself/herself through the internet. Redemption of points would result in the system sending a ‘Reward Voucher’ electronically to the whistleblower and a copy of the ‘Reward Voucher’ to the authorized person to exchange the ‘Reward Voucher’ with the actual Reward on presentation by the whistleblower. To ensure anonymity, the authorized person may be from a service provider.
	To further promote the speaking-up culture, a bulletin board has been provided in the system to display a message from the CEO as well as any other relevant contextual information. In addition, a facility has been built in that will result in sending promotion emails every month to the registered employees.
	The system allows concurrent operation of multiple theme based speak-up schemes in addition to the General Speak-up scheme. The theme based schemes are normally to address a specific serious problem and is usually time bound. An example may be that a specific super market has been facing unusually large variance between book stock and physical stock. A theme based speak-up scheme may be launched to find out the causes and plug the leakages.
	The system provides a dashboard with drill down facility that may be used for reporting. The senior management may also view the dashboard.

The barriers to the success of the Whistleblower schemes (Speak-up) are effectively countered by “iSuggestNow”.

	Fear:
	It puts the fear of reprisal to rest by enabling a whistleblower to post a speak-up from anywhere via a PC or a laptop connected to the Internet. Speak-up scheme administrator may also be receiving a speak-up in the written form that would be scanned and attached to a speak-up instance in the system initiated by the administrator. Similarly a speak-up instance in the system would be initiated in the system by the person who receives a speak-up on telephone or in a personal meeting/discussion. The system maintains complete anonymity and confidentiality of the identity of the whistleblower. In case ‘anonymous’ option is selected, email address of the whistleblower is not displayed to anyone.
	Processing & Status updates:
	Processing of a Speak-up is initiated immediately on receipt through an instant notification to the scheme administrator, resulting in faster processing of a speak-up. The whistleblower is kept informed of the progress through emails automatically sent by the system to the email address provided whilst submitting the speak-up.
	Transparency & Timeliness:
	The built in workflow enables monitoring of the progress of a speak-up through the assessment and approval process. In case of delay beyond the set norms, at any step, email reminders are sent to the step owner and the administrator. In case of excessive delay alerts are sent to the step owner, administrator as well as the designated higher authority.
	Employee Motivation:
	Any announcement on an accepted speak-up like a special reward may be made using the unique speak-up reference number via the email address specified in the speak-up or/and via the notice board. The reward scheme built in the system enables rewarding the employees contributing useful and relevant speak-ups, immediately. The system provides a facility to send emails monthly to all the registered employees emphasizing importance of speaking up.
As can be seen from above the iSuggestNow System counters all the barriers faced while implementing the speak-up scheme in the traditional manner. In short Whistleblower (Speak Up) scheme can be effectively implemented through iSuggestNow system.

A well implemented “Whistleblower Scheme” (Speak-up) would result in accrual of the following benefits to the organization in general and the Executive Management in particular.

	Safeguarding the organization against: o Potential Financial Leakages o Potential Loss of Good Will
	Preventing Penal action
	Bringing in culture of collective and collaborative working among the employees with its consequent benefits
	Meeting with the obligations of good governance

iSuggestNow - Whistleblower