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Is Your Hotline AAA-Rated?
Have you heard the one about the anonymous whistleblower hotline? After-hours calls go to a voice mailbox. They will call you back the next business day – if you leave your name and number. That's a pretty bad joke. But it's also a true story about a large organization that rolled out its new hotline when Sarbanes-Oxley (SOX) came into effect.
There's also the one about the CEO who boasted of how his company's new hotline had proven the high degree of integrity at his company: Since the launch of the hotline 6 months previously, they had received no reports of wrongdoing at all.
Many organizations have hotlines that are needlessly weak or even ineffective, and they often don't even know it. There are no up-to-date, authoritative standards for hotlines. This has forced SEC registrants and their auditors to use an unusually high degree of judgment in evaluating the effectiveness of hotlines for Sarbanes-Oxley ' 404 reporting. Non-registrants are even more vulnerable to “phantom hotline syndrome.”
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