Whistleblowing in global supply chains

October 12, 2023

The challenge

Supply chain whistleblowing will soon become a concern for Europe. Thus far having a whistleblowing tool for third-parties was not an explicit requirement for European organisations. The Corporate Governance Due Diligence Directive is about to change that by making complaint mechanisms for the entire supply chains of most EU organisations mandatory. While encouraging, this raises the following challenge:

How to select a whistleblowing solution that works for everyone?

Selecting the right whistleblowing solution for your organisation is already tricky as it is. In parallel with organisational culture and capacities, you have to carefully examine your employees. Any tool will be useless if it is not successfully adopted and openly used. Now add suppliers to the equation and you get a real problem.

When it comes to your own employees, you will likely consider things such as company culture, resources, as well as employee demographics, needs, and preferences. But can you do the same for third-parties? How can you cater to people who are complete strangers? After all, the supplier of your supplier’s supplier could be on the other side of the world. They most probably don’t speak the same language as your compliance team and have little to nothing in common with your employees.

Therefore, how can you make the most informed decision for a whistleblowing tool which ensures that anyone affected by your operations will speak up?

The Solution

It would be impractical to try and determine the exact dimensions of your supply chain. Instead you should aim to create policies and to implement solutions which help you identify and deal with potential violations, no matter where in your supply chain these occur. The distance between your organisation and the incident is what makes this an admittedly hard problem to solve. However, by focusing on some key aspects of whistleblowing, you can narrow the gap.

The topics discussed below are not limited to supply chain whistleblowing. On the contrary, we have always described them as fundamental for effective misconduct reporting. The EU Supply Chain Act is an excellent opportunity to bring these elements back under the spotlight. 

The key elements

Similar to traditional misconduct reporting, there are two sides to consider when it comes to supply chain whistleblowing: the reporters and the case-handlers. Let’s start on the reporting side. In the context of the EU Supply Chain Act, the reporter could be any stakeholder in your supply chain. With a wider audience, you will need a tool that can be adjusted to appeal to more people.


1. Language coverage

The first and, maybe, most obvious topic is language. Considering that the boundaries of your supply chain could be anywhere around the world, you should be able to receive concerns in as many languages as possible. Consequently, a mechanism only available in a limited number of languages could be problematic.

2. Accessibility

Intertwined and equally important with languages are the reporting options. You should understand that people down your supply chain will have different educational and literacy levels. Some may be more and others less familiar with technology than your employees. Therefore, make sure to opt for a reporting mechanism which can be accessed relatively easily, and this via various means.

While a simple web form or a modern mobile app could perform well internally, these will most likely not be efficient for your entire supply chain. What about people who have no access to a mobile phone, a computer, or the internet? Make sure that your selected tool can be accessed with or without an internet connection.

This is exactly why old-school phone reporting is still vital. Even so, try to avoid outdated and high-barrier hotline centres. A hotline obviously creates unnecessary interpretation difficulties. More importantly, it creates the risk for people to abandon the reporting process entirely. Having to interact with and to confide in a stranger is an unnecessary obstacle.

Instead of a hotline, you should opt for an anonymous, automated voice-recording phone system. This allows people to easily and safely share their concerns at their own comfort. In addition, make sure that your provider’s coverage of phone lines is wide enough to reach even the most remote parts of your supply chain.

3. Flexibility

The flexibility of the reporting journey is equally important in supply chain whistleblowing. You might need to collect more information before you can deal with an external, faraway concern. To do so, you need to be able to adapt your mechanism. Is your current reporting process a fixed and lengthy questionnaire? Some questions will not be relevant for everyone. You should opt for a tool which allows you to collect the information you need without scaring people away. Prioritising an uninterrupted dialogue is the way to achieve this.

4. Anonymity

Last but not least, remember the vital importance of allowing the reporter to remain anonymous. Aim for a solution that provides the anonymous option while simultaneously attending to its potential risks. Read more about optimal use of anonymity here.

Naturally, an expanded field of use of the tool will likely increase the number of reports received. To maintain your whistleblowing programme’s integrity, you must also aim for enhanced case-handling functionalities. While attempting to reach your supply chain, the next few elements will help you deal with what you sow.


1. Message interpretation

Being able to receive messages in multiple languages is futile if you’re not able to understand them. This is why a qualitative processing of messages is an absolute necessity for your whistleblowing tool. The most powerful anonymous communication platform is one which integrates both qualitative transcription and translation of messages, as this is your best shot at establishing an effective dialogue with people.

Technology is constantly advancing and automatic (machine) transcription and translation is at a good level. Nonetheless, people’s different backgrounds will be reflected in their communication skills. And when it comes to such sensitive issues,  it’s absolutely crucial that the content of messages remains intact. Therefore, it’s best that you implement a whistleblowing tool which reinforces automatic interpretation functionalities with qualitative, human efforts to be used when and if needed.

You must, however, ensure that such processing of messages does not jeopardise compliance. Aim for a tool that integrates GDPR-proof transcription and translation.

2. Case management

Improving the quality of the dialogue must be complemented with proper case-handling. To stay ahead of all your case management needs, it’s best that you use a whistleblowing mechanism which concentrates everything you need in one single space. Your tool should provide a clear, global overview of all your channels, internal and external.

Moreover, you should opt for a solution which allows you to create and manage case-handling teams according to your case-handling needs. You should be able to know if a case comes from someone in your supply chain, while you should also be able to assign this case to whoever can handle it best.

Your supply chain whistleblowing solution should also come with straightforward access controls. It’s important that you keep track of which team has access to which data for you to maintain a smooth but effective workflow.

3. Reporting and risk management

Similar to other recent due diligence initiatives, the EU Supply Chain Act requires that you measure the effectiveness and publicly communicate on your due diligence. While we know little about what the exact public reporting requirements will be, there already exist other EU legislations that demand certain considerations.

For example, the Non-Financial Reporting Directive (soon to be replaced by a Corporate Sustainability Reporting Directive) requires that large organisations publish information related to environmental and social matters, treatment of employees, respect for human rights, anti-corruption and bribery, among other things. Along these lines, it would be wise to opt for a whistleblowing tool which can facilitate data visualisation. Make sure that you can filter and extract system data, as needed.

As expected, the addition of your supply chain also expands the scope for risk management. Next to data visualisation, make sure that your tool’s data is also suitable for your risk management tools.

4. Third-party communications

While dealing with all the above, you should not neglect communication. You could have an excellent whistleblowing tool; but if no one knows about it, no one will use it. You must carefully reflect on how to reach people all over the world. Find a solution that makes it equally easy for anyone on your supply chain to become aware, to understand, and to complete the reporting process.

To achieve this, put your trust in a whistleblowing provider who has expertise with big multinationals. These are organisations who have already faced and have overcome the challenge of a globalised whistleblowing programme. Take advantage of the best practices of other organisations. You can quickly gain a lot of valuable insights.

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