It must be the worst feeling in the world to get a call like this;

“Hi this is John Smith from the Financial Telegraph and we would like to speak to you about a cover up in your organisation. We are running a story tomorrow and are offering you the chance to comment …. “

We can all think of the household names that have been caught in the cross-fire of scandal recently and I am sure we all have a view on how it could have been handled better.

The truth is, that once a concern is raised externally, the ability to investigate, evaluate, report, remedy and improve controls is out of the company’s hands. It is full on firefighting mode and decisions made in the heat of incident management are rarely long term strategically aligned to an entities values and mission statement.

Speak up…

If the new whistle blowing rules are embraced and the right frameworks are put in place to ensure relevant people have clear roles, expectations and accountability, the C-Suite executives can share (i.e. delegate) the burden of accountability with their colleagues. This includes the logging of details and the transfer of responsibilities to those holding named roles.

Default to the top…

If the frameworks are not put in place with governance, controls, reporting and tracking, then the accountability will automatically revert back up to the top of the firm.

On that basis it is in the interests of the Chief Executive / Chief Financial Officer / Chief Risk Officer / Chief Compliance Officer and all the other chiefs to build the relevant frameworks and ensure they are policed with rigour and diligence.

It’s good to share…

If you are a more junior senior manager, it is in your interest to ensure that the responsibility bestowed upon you is clear and that you are able to demonstrate a control framework around you that is robust and effective.

Where to start…

We recommend that companies start with good foundations (risk appetite statements and risk assessments) and then build out from there. The framework will only be as strong as its weakest link, therefore it must be consistent from the top down and maintained over time to ensure accountability is clear and transferred as people move around the organisation.

If your firm completed a Senior Managers’ Regime (SMR) exercise a year or so ago, you may want to get that folder back off the shelf, blow the dust off it and check to see who has moved jobs or left in the last 12 months and ask:

• Who has that role now?
• Did they sign a transfer of accountability form when they took the role?
• Do they know what accountability they received with the role?
• Did they relinquish accountability from the role they vacated?
• If the role is vacant, then does the role’s boss know they are accountable until it is filled?

This is exactly the type of task that slides down the priority list. But you and your organisation could be next in the firing line. Having the right whistle-blowing strategy and processes in place will help identify any problems before they have a chance to blow up, leaving you to resolve them in a considered and thoughtful way.

For further information please email phil@p2consulting.com or call +44 (0) 20 7099 0803.