Investigating without a complainant, and deciding how far to go.
Esshaki Legal Media TeamCurrent as of October 2021
Anonymous reports arrive through hotlines, letters and emails. They cannot be
ignored, and they cannot always be resolved.
Assess the specificity. A report with names, dates, amounts and documents
can be investigated. A general assertion that something is wrong in a department
usually cannot, and the response should be proportionate.
Do not attempt to unmask the reporter. Investigating the source rather than
the allegation is retaliation in substance and is treated as such.
Follow-up mechanism. Good hotline systems allow anonymous two-way
communication through a case number. Use it to ask clarifying questions, which
frequently converts an unactionable report into an actionable one.
Corroboration. Documents, systems data and transaction records can
substantiate a specific allegation without any complainant.
Document the assessment. Where a report cannot be investigated, record why,
what was considered, and what monitoring was put in place. An unexplained
decision to take no action is the finding.
Pattern analysis. Repeated anonymous reports about the same area, each
individually thin, are collectively significant and should trigger escalation.
Feedback. Where the channel permits, tell the reporter that the matter was
reviewed. Reporters who hear nothing go elsewhere next time.