Does Your Ethics & Compliance Program have a Net Promoter Score?

Written by Ellen Hunt, PRINCIPAL consultant and advisor at spark compliance

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Would someone who came to the Ethics and Compliance Office refer a friend? 

Almost all companies track their customers’ experience, usually by a net promoter score, with referrals from promoters being the best source for attracting and retaining customers. A net promoter score is calculated by asking if:

“On a scale of one to ten, how likely are you to recommend the Ethics & Compliance Office to a friend or colleague?”

Those who answer 9 to 10 are promoters who are most likely to make referrals.

Using this same framework and mindset, Ethics and Compliance professionals can learn a lot about how those that utilize their services (i.e., your customers) feel about their experience. 

Why wouldn’t you want to know if that experience was good or bad?  

This knowledge, just like other information sources, such as employee engagement surveys, hotline metrics, and training statistics, can inform on what is being done well and what aspects of the Ethics & Compliance Program need improvement.  

Better than Employee Survey Data

Employee surveys often ask general questions about fairness or perhaps you have been lucky enough to include a handful of specific questions about the Ethics and Compliance Program. 

While valuable, this information often falls short of providing actionable and meaningful information about the customer experience since the audience may or may not have utilized any Ethics & Compliance Office services. 

Therefore, how relevant is it that they may know who the Compliance Officer is or how to report a concern? Until someone has a concern, does it really matter if they say that they would report it?  

Speak Up, Now What?

Amidst the fanfare of our Speak Up campaigns is the nagging question of what happens when someone does. Often the investigation process is a black box with an unexplained process cloaked in confidentiality so that those that do come forward have no idea of what will happen next.

Would you buy a car without researching its safety record?  

Would you consent to a medical procedure without understanding what the recovery might be like?

No, hardly anyone would.

But this is the position that we place on those that Speak Up. As savvy consumers, we all jump on Yelp before making reservations and we all read Amazon reviews. But what information is available to those that want to raise a concern?

Why would anyone choose to raise a concern when they don’t know what will happen next? 

More importantly, why would anyone take the risk of raising a concern when they don’t know how they will be protected from retaliation? 

Saying that there is zero tolerance for retaliation is not a proven safety record that it hasn’t or will not happen. However, a customer that refers a friend to the Ethics & Compliance Office is.

All Concerns Are Taken Seriously

Because we often don’t connect the dots for those involved in the investigation process, those involved are left to fill in the blanks themselves. 

It is like placing an order on Amazon but having no ability to track when it might be delivered, if at all…

If you haven’t told them that the investigation has been concluded and what the result was, they will assume that nothing has been done and the promise that “all concerns are taken seriously” becomes as meaningless as the warnings on coffee cups that the contents might be hot.

6 Steps to Improve the Experience 

There are six simple steps to take to improve and learn more about your customers’ experience.

1. Remove the Mystery

Understand that being involved in an investigation whether you are a manager, an interviewee, the reporter, or the accused is not an everyday occurrence. Even if familiar with the process, it is stressful and anxiety-provoking.  

Enhance the customer experience by informing all of those involved about the process, how they can ask questions about the process, and when they will be communicated with.

Don’t just go over these details at an initial meeting, provide them with a resource that they can reference later. Better yet post this resource on the internal Ethics & Compliance site so that it’s available to anyone at any time.

Knowing what happens after reporting a concern might just be the information someone needs to make this important decision.

2. Set Expectations

The concern may not be the most critical issue for the Ethics & Compliance Office, but for those involved, it may be all that they are thinking about.

For the manager, the investigation may not only be a disruption but impact the ability to meet goals and milestones.

For others, they may fear that they will lose their jobs, lose the trust of their co-workers, and suffer reputational damage.

Be as clear as possible about timeframes and set expectations. Everyone can understand that investigations take time and how much time it takes might not be controlled by the Ethics & Compliance Office. All can agree that being thorough and complete is the goal rather than meeting an arbitrary deadline.

There may be expectations that the Ethics & Compliance Office cannot meet for a variety of reasons. Asking what the expectations are early in the process can help avoid misunderstandings and perceptions of a biased and unfair process.  

3. Answer Before They Ask

Check in regularly with those that are involved. 

Instead of waiting for them to ask what the status is, let them know. This reduces the anxiety that nothing is being done but also shows that in fact, the concern is being taken seriously. 

4. Share the Results

There are, of course, limits to what you can share but de-identified reports about the number of concerns raised and how they were resolved can go a long way in demonstrating that concerns are investigated and that corrective measures are taken.

Average close closure rates can help with setting expectations about timeframes. 

5. Follow Up

We tend to think that after the investigative report is issued, the matter is closed.

This is not so.

There could be relationships and trust within the unit that must be repaired. Perhaps there needs to be training on specific policies or procedures. Other corrective measures besides discipline may need to be implemented. Those that were involved may feel that they are being treated differently or retaliated against. 

Follow up with personal communications to determine how it is going.

6. Develop the Net Promoter Score

Use tools that you already have, such as Survey Monkey, to send a short survey to all that were involved to develop the net promoter score. Ask what the experience was like and how it might be improved. Ask if they would refer a friend. 

Developing a net promoter score can provide the Ethics & Compliance Office with actionable information that is specific to its customers, gives direction for change and improvement, and can be tracked over time. 

It may even serve as a powerful marketing tool when customers make referrals to their friends.


Email Ellen at ehunt@sparkcompliance.com for further information or Contact Us at Spark Compliance here.