The Sound of Silence

• Acknowledge your own fallibility/Lead with humility

Research has found that humility in senior leadership encourages stronger leadership behaviours from other senior leaders and middle managers within the organization (Ou, Tsui, Kinicki, Waldman, Xiao, & Song (2014)). Humble leadership also improves decision-making, increases employee engagement, and enhances on-the-job performance (Dowden, C. (2015)).

One technique Edmundson suggests leaders can leverage is to make simple qualifying statements when discussing group work such as "I may miss something — I need to hear from you.”

• Model curiosity by asking a lot of questions.

A great way to further formalize these goals is through asking lots of questions, as it requires the team to speak up and share possible solutions or alternatives. It is important that these questions be framed in a learning rather than judging mindset to maximize engagement and not be presented in a leading manner. For example, rather than asking “Don’t you think it would be better to do it this way?” use “What do you think is the best way to do this?”

2. PROMOTE CLARITY AND COMMUNICATION

the chances people will go outside the organization, which can bring more scrutiny and potential consequences (Sunday (2015)).

Other studies have shown that although employees generally try to deal with their complaints internally, they will seek outside counsel and support should they feel that their organization is unresponsive (Barnett (1992)). The following lists several ways to improve clarity and communication within departments:

• Build capacity in leaders to help them communicate regularly and with clarity. Interviews with PSIC personnel identified some situations where a disclosure of wrongdoing turned out to be the result of miscommunication. In these cases, well-meaning executives could be unwittingly creating concerns in their teams by their inability or unwillingness to communicate.
• Clearly explain and communicate criteria for appropriate cases for blowing the whistle. Employees should be given as much information as possible concerning what constitutes an appropriate case. This information could be shared internally, by both leaders as well as Senior Disclosure Officers (SDOs). Comparing their case within these parameters would help maximize the confidence employees feel about the legitimacy of their report.

An important part of this education process would be to share successful and unsuccessful cases within and across departments so people could learn from these experiences.

Clearly explain and communicate the internal process for bringing forward their concerns. Not surprisingly, a key element of success is to ensure employees are informed of the appropriate steps to take in communicating their concerns internally (Barnett (1992)). The importance of this recommendation cannot be understated, since studies of federal government employees show that there is a significant association between employees' knowledge of appropriate internal channels and the likelihood that they will report perceived wrongdoings (cf Barnett (1992)). Also, a recent audit conducted by Public Safety Canada showed that 50% of respondents reported feeling uncomfortable raising issues related to disclosing wrongdoing with their SDOs (https://www.publicsafety.gc.ca/cnt/rsrcs/pblctns/2014-ntrnl-dtvls-thcs/index-en.aspx). This is very disconcerting, given that this is the very reason these roles exist. It should be noted that in the same audit, people also noted their confusion about what the role entailed.

• Since research suggests experienced employees tend to be more inclined to blow the whistle, promoting this type of clarity may be especially important for younger members of the organization. Departments could incorporate whistleblowing into their onboarding materials and processes. Specifically, departments could provide the name and contact information for the local SDO, along with a description of their role within the department in the written materials/onboarding package. This would provide junior employees with critical information and also strongly signal the importance the department places on doing the right thing. As part of the onboarding process, a meeting could be set up between the new employee and the SDO to establish an initial relationship.

3. FOCUS ON FAIRNESS

Research strongly suggests that when individuals focus on fairness, they are much more inclined to blow the whistle than when they focus on loyalty to the group and/or organization. There are various ways leaders can maintain a focus on fairness:

• While speaking with their group about hypothetical situations where disclosure is required, a leader may share the following “although it is understandable you may feel that you are being disloyal and maybe even betraying the team, your colleague(s), or the organization, what is most important to remember is honouring our obligations to the people of Canada as well as to each other. Speaking up is not about punishing someone or making our lives more difficult, it is about ensuring we are doing the right thing and feel comfortable sharing dissenting opinions that are in the best interest of Canadians.”
• Another strategy for reframing this issue may be to view whistleblowing as demonstrating a “larger loyalty" (Rorty (1997)), which corresponds to the notion of serving the greater good. Expanding the frame in this way may allow effective reconciliation between the competing drives of fairness and loyalty (Waytz, Dungan, & Young (2013)), which may place a more positive view on disclosing wrongdoing.
• Another possible tactic may be to ask employees to consider how might they be perceived in the future by their colleagues if they choose not to act. This could motivate individuals to examine the situation from a different perspective where they could possibly recognize the downfalls of not speaking up.
• Lastly, it is important to note a key, yet possibly missed, element of the fairness versus loyalty trade-off. Underreporting may also exist in the areas where you least expect it; under nice and/or supportive leaders. The reason for this seeming disconnect is that employees may not want to report incidents of wrongdoing because they are afraid their leader may be reprimanded. Employees may prefer to put up with an offensive colleague, because they worry that things might change under a new leader. They may also worry that disclosing wrongdoing to their leader may provoke a change in style, where the leader will become more abrasive and unapproachable.

Supporting this idea, Mesmer-Magnus and Viswesvaran (2005) speculated that the weak negative relationship reported between “supervisor support” and actual disclosure behaviours exists because employees may desire to protect their generally supportive supervisor.

4. BEWARE THE PERIL OF INCENTIVES

• Look beyond the numbers when conducting performance evaluations. When you rely heavily on management by objectives, it can lead to a situation where leaders reinforce the idea that “what” was achieved is far more important than “how” it was achieved. While this approach has been championed because it supposedly removes ambiguity and biases from the appraisal process, experts argue it may inhibit or eliminate our capacity for ethical reasoning, since we employ numerous rationalizations for our behaviour (e.g., “The system made me do this”). It provides an easy way to act unethically without recognizing our responsibility for these behaviours (Anand, Ashforth, & Mahendra, 2004). Although some departments and agencies are starting to pay more attention to the “how” of performance management, this needs to be a top priority moving forward.
• Some individuals have argued for the utilization of financial incentives to encourage disclosure of wrongdoing (Boz,, Maysaa, & Morrison (No Date)). However, despite its intuitive appeal, this recommendation is not supported by the existing evidence.
• A recent report entitled Financial Incentives for Whistleblowers, which was produced by the Financial Conduct Authority and the Prudential Regulation Authority for the Bank of England concluded after conducting research into the use of financial incentives by US regulators that “There is as yet no empirical evidence of incentives leading to an increase in the number or quality of disclosures received by the regulators.”
• Other research suggests offering financial incentive may even have negative effects. For example, Deci, Ryan, & Koestner (1999) reviewed 128 experiments conducted over almost three decades and concluded that “tangible rewards tend to have a substantially negative effect on intrinsic motivation. When institutions... focus on the short-term and opt for controlling people’s behaviour, they do considerable long-term damage” (page 39).
• In one particularly relevant study for how incentives impact our motivation to do the right thing, researchers examined the impacts of incentives on individuals who were interested in donating blood to a local clinic. Some of the participants were paid while others were told it was voluntary. The results showed that the incentives had either a null effect or actually decreased the desire of respondents to give blood, particularly among women (Mellström, & Johannesson (2008)). This highlights how incentives do not increase our motivation to do the right thing and can actually counteract it in the federal public service.

5. SENIOR DISCLOSURE OFFICERS

Almost every department has a SDO who is responsible for supporting employees considering disclosing wrongdoing (Each organization is responsible for their own disclosure procedures, the majority of whom appoint a SDO. However, due to the nature of their size, some small organizations do not. In this instance, employees still have the option to directly approach the Public Sector Integrity Commissioner to make a disclosure or to seek advice.). The following suggestions highlight opportunities to strengthen the role to maximize its effectiveness:

• Create formal selection criteria for SDOs. Currently, there are no widely used formal procedures to aid the selection process for these key roles. Anecdotal evidence gathered through our interviews suggests that in some cases, the appointments appear random.

Formal guidelines could prove invaluable to ensuring the right people are selected. These criteria could be developed within each department, which could also determine the key roles and responsibilities attached to the position.

A potentially more valuable approach would be for a centralized body, such as the Treasury Board Secretariat, to create universal standards for selection. This would ensure that each department follows similar procedures, maximizing consistency of the system. It would also provide added legitimacy to the role. Unclear or inconsistent selection criteria may send the unintended message that these roles are ceremonial rather than fundamental priorities of the organization.

• Incorporate psychometric/other assessments when deciding on candidates for the SDO position. Evidence suggests that certain personal/personality factors affect the willingness of individuals to speak up. Also, if the wrong person is put into the role of SDO, one bad reporting experience by an employee can have an enormous impact on the willingness of others to step forward.

Thus, it may be prudent for departments to incorporate some form of psychometric assessment into the selection process to measure these characteristics. It is logical to assume that certain attributes such as assertiveness, sense of duty, trustworthiness, tact, empathy, etc. may be important for success in a SDO role.

• Provide SDOs with additional training about what to expect, what is expected, and keys for their success. Also, there is a lack of consistency in the training received across Departments. This represents a great opportunity to create a more integrated training regimen.
• Sponsor qualitative research focused on SDOs to determine key success factors for the position and select accordingly. Once again, individual departments or a centralized body (e.g., PSIC or TBS) could sponsor qualitative/survey research designed to identify the key success criteria for this role. This information can be gathered through consultations with current SDOs and/or by asking employees the kind of profile they feel is important (or both). Another idea may be to conduct a jurisdictional scan to explore whether other areas are using these roles and how they are managing them.
• Remember that appointments alone are not enough. Despite the importance of the SDO role, the evidence strongly suggests this practice alone is insufficient. Specifically, while individuals who are assigned to these kinds of roles enthusiastically report their willingness to act, even they can fail to step forward when necessary (Miceli, Near, & Schwenk (1991); Near & Miceli (2008)). Organizations and senior departmental executives would be well served to ensure ample support and resources are provided to these key “watchdogs” so they can effectively deliver on their commitments.
• Be aware of and sensitive to the potential conflict SDOs may face. Although individuals are assigned to the SDO role to ensure wrongdoing is appropriately handled and reported within departments, senior executives should be aware of the potential conflicts and concerns that these individuals may struggle with. For example, SDOs may still fear reprisal from colleagues, even though they are mandated to manage these investigations.

As a result of this fear, and without sufficient guidance, individuals in these positions may (wrongly) believe their primary responsibility is to ‘‘save face’’ for the organization by covering up the acts or by intimidating or discouraging the whistleblower. Despite their appointment to a ‘‘watchdog’’ role, without concrete guidance or clear expectations and responsibilities, SDOs may not fulfill the obligations attached to their role (Mesmer-Magnus & Viswesvaran, (2005)).

• Ensure high visibility of the SDO role. During our interviews, it was unclear the extent to which people were aware of the role of SDOs. This identifies an interesting opportunity to conduct research to find out how visible this role is within the organization. A recent audit on Values and Ethics conducted by Public Safety Canada lends credence to this hypothesis; they reported that only 50% of respondents reported feeling comfortable reporting to their departmental SDO (Readers who are interested in reading the complete report can find it here: https://www.publicsafety.gc.ca/cnt/rsrcs/pblctns/2014-ntrnl-dtvls-thcs/index-en.aspx). This is quite discouraging, given the primary function of this role. Departments may want to reflect on how they currently inform their employees about the existence of these roles and identify ways in which to increase frequency of communication and clarity.

6. HOLD PEOPLE ACCOUNTABLE

• Countless people we spoke with highlighted the exceptional frustration that occurs when inappropriate/unethical behaviours are brought to light. In almost every case, the executive receives a “slap on the wrist” and/or “gets moved.”

This sends a chilling message that executives only care for their own. To truly transform the federal public service and foster employee voice, it is essential that individuals, and especially executives, are held accountable for their behaviours. As noted by several interviewees, executives are non-union, so there is an open question as to why these individuals are not fired or, at the very least, demoted to a non-leadership role.

The importance of accountability when it comes to creating a culture of speaking up was powerfully expressed by Kleinhempel (2011):

“Effective treatment includes corrective steps to remedy the consequences of reported wrongdoing and adequate punishment for culprits, regardless of their job title and their relevance for business success. The entire organization is watching when a company investigates a misconduct report, reading into every sign and measure to gauge top management’s sincerity and commitment. Internal justice, rewards and punishments provide a set of criteria for employees to measure just how ethical their organization is and act accordingly.

Taking employees’ complaints and reports seriously shows a face of corporate culture, and, at the same time, sends a strong signal to encourage potential whistleblowers.

Whistleblowing programs may be beautifully designed, but they only prove effective if they reflect the true culture the company embraces day in and day out through management behavior and the values conveyed by example.”