i2 Ethics blog

Fomentar la Cultura Corporativa: Adelantarse al regulador

adelantarse al regulador



Una cultura corporativa que fomenta la divulgación y la observancia de las obligaciones de la empresa, unida a un programa de protección de denunciantes, son elementos importantes para detectar comportamientos irregulares o ilegales.




  • Las empresas deberían considerar si cuentan con una sólida política de gobierno corporativo que fomente la denuncia de conductas irregulares e ilegales.
  • Los empleados necesitan tener la confianza de que no serán victimizados por hablar. Las empresas deben establecer procesos para proteger a los denunciantes.
  • Las empresas deben asegurarse de que su personal reciba capacitación sobre la importancia de la divulgación y sobre los procesos existentes para protegerlos. Los directivos de la empresa y la dirección también deben recibir capacitación sobre cómo tramitar y resolver las denuncias.

Las empresas que operan con programas sólidos de Canales de denuncia son más propensas a erradicar la potencial irregularidad y la delincuencia antes de que ocurra o se denuncie a las autoridades.

Exponer las faltas en el trabajo puede colocar al denunciante en un territorio traicionero. Las denuncias siempre han sido un terreno fangoso para aquellos valientes con principios suficientes para exponer actividades ilegales o poco éticas dentro de una organización. El proceso puede conducir al aislamiento, el acoso, las oportunidades de trabajo perdidas y las transferencias de lugar de trabajo forzadas. En casos más graves, un trabajador puede descarrilarse por el despido, iniciar acciones legales e incluso llegar a la agresión física.

Minimizar parte de ese estrés es posible cuando los empleados pueden dirigirse a una “persona objetiva, independiente" al considerar sus opciones.

i2 Ethics puede recibir información confidencial de una persona que desee informar sobre posibles acciones ilegales o incorrectas en su organización asegurando que las denuncias se puedan hacer de forma abierta o anónima.


En nuestra experiencia 2 de cada 3 denunciantes buscarán el anonimato ante la entidad.

El sistema i2 Ethics permite a sus empresas clientes decidir si los usuarios de su canal de denuncias pueden permanecer anónimos frente al ellos. Este sistema obtiene lo mejor de los dos sistemas:

  • El denunciante se encuentra más cómodo sabiendo que puede elegir no compartir sus datos personales con la empresa.
  • La empresa está tranquila ya que el sistema cumple la legalidad, no pierde la posibilidad de retroalimentación como en el caso de las denuncias anónimas y de esta forma puede obtener más y mejores resultados.


i2 Ethics ha desarrollado una plataforma con bases de datos aisladas de información segura que permite una gestión confidencial y precisa de las denuncias de acuerdo con los requerimientos del cliente. La base de datos mantiene toda la información necesaria relevante para la comunicación individual y permite que los informes dirigidos al cliente se generen de acuerdo con sus necesidades.

En un mundo ideal, las compañías y las organizaciones crearían las culturas que animan a los empleados a hablar internamente, sobre asuntos de la mala administración, de la corrupción y de la ilegalidad.

Construir una mentalidad en el lugar de trabajo que promueva la comunicación abierta podría influir en otras áreas, mejorando la innovación, la retención del personal y los niveles de productividad. Abrir la puerta a los empleados también puede proporcionar a los directivos de una empresa un sistema de alerta temprana antes de que los desacuerdos progresen y se vuelvan difíciles de gestionar.

Estos son solo algunas de las claves de la importancia de tener a una organización externa gestionando su canal de denuncias. Hablaremos de muchas más, en los próximos post.

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Six key points to generate trust in our Reporting Channel

Top 10 factors leading to hotline distrust by Ryan C, Hubbs & Julia B, Kniesche
Fraud-Magazine.com – July/August 2016



Companies implement and maintain reliable reporting channels differently depending on their sizes, cultures, geography and other factors. They should also decide whether they will build their channels internally or if they are to be outsourced.

There are numerous advantages in outsourcing this service, as experience and neutrality, which can increase the employees’ confidence in reporting channels. A good provider should allow accessibility 24 hours a day and 7 days a week, and offer additional services or add-ons (such as Call Back, consultancy, contents dissemination... etc.).
However, small organizations may believe that to do it internally is the easiest and cheapest option, and this is not so. Without going into confidentiality issues of the people who are responsible of receiving complaints, we must consider that we should establish an internal program that will require a significant investment in hardware, software and in qualified personnel to start, plus the ensuing upcoming expenses.
One way or another, the management must remain independent and should only intervene if an investigation is begun. External consultants, including Certified Fraud Examiners, can help an organization to implement a fraud analysis plan and help to implement continuous improvements in solved cases.
But, apart from the correct implementation, we must measure our channel use of the reporting cannel and its integration into the company. These are the six main points we have to be absolutely clear for the creation of a solid trust and stable culture:

1. Education and training
We must strive so that our employees understand the reporting channel, thus we help to build trust in the system.
An organization should train its employees in handling reporting channels, why does the organization believe this?, who manages it? and why are they a critical part of the compliance culture?
2. Continuous communication
Communication about the existence of a reporting channel, recent compliance publications and management messages should be regular and natural. All this is then reflected in the amount of accesses to the channels.
3. Accessibility
Access to a reporting channel should be within the company’s website, intranet or it should be external to the organization, but always under the premise of being accessible and confidential.
The channel information must be communicated in as many languages as necessary to provide the desired coverage.
4. Transparency
Which will explain the investigation process after receiving a complaint, find out what the employee expects from the reporting channel, report on the responsibilities of the organization to cooperate and protect against possible reprisals... etc.
It is necessary to reduce any uncertainty about the service.
5. Competence and objectivity
Those who manage the reporting channel and investigation processes should be duly accredited professionals who are well trained and experienced in handling complaints. If necessary the organization should also install and implement adequate systems, processes and technologies to support researchers and employees.
6. Evaluation
Once the reporting channel is implemented, we must evaluate it periodically in response to the following questions:

- How do the employees see the reporting channel and the compliance culture from our company?
- Does our channel meet the employees’ needs, both in content and usability?
- Do reports of channel usage and complaints reports are well designed and are responsive to our needs?
- Are investigations and resulting disciplinary actions consistent with the desired compliance culture?
- Are all complaints and resolutions revealed and spoken with external auditors?

If our employees want to do the right thing, we must put all our efforts to help them, support them and encourage them to speak out and get involved in the smooth running of the organization.


Our employees could be the key to detect future problems in our company.


Your company can have the best valued tool at fraud detection, we offer customized plans depending on your needs and budget

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Reporting channels in Spain: Do they work or not?

Published by Diario Responsable in 18/04/2016

Spain is different… again.


The cases concerning corruption have tripled in the last decade. Everyone calls for better laws and improving control mechanisms to stop this flow of ceaseless, 

b2ap3 icon b2ap3 icon canalesdedenuncia

tiresome and corruption inside and outside: in private, business, public, political and institutional sectors. But when we have the right tools at our disposal, we belittle them and we make void the grounds telling that they are no use, that they are not effective or that they malfunction... because in Spain we are different.

We are not Anglo-Saxons, in our culture to "snitch" does not enter the mobster code that keeps us together as a society. Reporting channels reduce the business average loss caused by fraud and corruption in half, but in Spain we still say that "these systems do not work, I have a channel in my company and I receive a complaint a year" (literal sentence of a company’s CEO with more than 10,000 employees).

Do they work or not? Let's clear up the doubt once and for all. Let's see:

Fraud is pervasive and does not discriminate so, unfortunately, there is no company that is free from it. According to ACFE, the most prestigious anti-fraud association in the world, as different studies collect their Report to the Nations, "more than 40% of corporate fraud cases are detected by reports from employees themselves." In fact, reporting channels are the fastest and most effective method to detect fraud, far ahead from other prevention tools such as audits.
Controlling fraud is not only something already required by law, but its outsourcing should become a priority for the responsible management of any organization. Spanish prosecutors themselves establish in their recent circular that the reporting channel is a mandatory tool in the compliance plan of any company.
Compliance plans are a firm commitment to a "regulated self-regulation" formula in the fight against crime. The criminal liability of corporations, as legal persons, affects not only the crimes committed within their organization, but also those who may commit third parties such as suppliers, subcontractors or freelancers who provide services to the company.
Therefore, it is not only necessary to have a system of reporting irregularities to protect the one who complaints, but fulfills its function of preventing the commission of crimes, including those:
- Crimes against privacy and computer trespass
- Proper and improper Scams
- Punishable insolvencies: risings and punishable contests.
- Damage and computer hacking
- Crimes against intellectual property.
- Crimes against the market and consumers.


A parent who does not want his/her child to watch TV tells the child, "the T.V. does not work". The parent does not care if the T.V. is really working or not, he/she doesn’t want her/his son/daughter to use it. So I tend to think that perhaps the businessman who claims that his/her company’s reporting channel does not work perhaps what he/she precisely wants is not to be used by anyone. Out of sight, out of mind. Very Spanish.
We are all fed up with abusers, from those who take something that does not belong to them and which hurts everyone, not just the company. Corruption and fraud in companies, apart from the economic losses that they cause, they also damage the employees’ morale who do things correctly, damages the faithfulness of those who believe in your company and which are committed with doing things right.
We have the perception that in Spain enterprises don’t report. That's because in our country more than 95% of companies still don’t have/or have never had a mechanism control by which they could "raise complaints" without fear of reprisals. And within the 5% that does have an ethical line, half have bad implanted mechanisms, which mean that they are designed to "discourage" their use and not to encourage them for their sake.
If one day going to the office and "the meter doesn’t work", you may wonder, it doesn’t work now, but will work later?, when? And most importantly, why doesn’t it work? All these questions should be those who have complaints mechanisms in their companies and believe that they are not useful

The reporting channels are effective and work when you want them to work.

  • A bad mechanism is interpreted as a deterrent message by employees.
  • A bad mechanism increases the distrust among employees.
  • A bad mechanism leads to complaints’ management irregular situations.
  • A bad mechanism makes the defendant to become aware ahead of time.
  • A bad mechanism makes the company not to really know is what is happening internally.
  • A bad mechanism encourages the bad employee’s sense of impunity.
  • A bad mechanism can lead to dock the company.


When channels don’t work, why is that?

  • They have not adequately communicated that throughout the organization.
  • They have not given adequate training.
  • They don’t make reminders to employees to show the organization’s commitment.
  • There is no real commitment from the company.
  • They have already implemented it internally through the CRM or resident in the intranet.
  • Internal networks are safe against strangers from the company but that does not "feel" of security to employees.
  • People who receive complaints internally are several within the same operating department.
  • People who receive complaints are from the management’s trust but not from its employees.
  • On more than one occasion the accused is informed "informally" by third parties that he/she has a claim against him/her.
  • Accessible only to make a complaint through the company’s intranet.


When channels work, why is that?
The decision-making process at all levels of the company is geared to compliance.
Managers promote with their example a real culture of compliance.
There is a clear commitment from the company’s senior management to prevent the commission of crimes and a clear support to the compliance program.
Behavior and involvement of the Board of Directors and senior executives moved a culture of compliance to the rest of the company.
There is no hostility of managers towards compliance programs.
Management messages in this matter are clear and unambiguous and do not imply ambiguity or indifference.
There is no management conduct that allows subordinates to interpret that is worth taking the risk of unfulfilment in exchange for the greatest economic benefit.
The company’s primarily responsibles do not violate the prevention and control model.
Management does neither reward nor incentive, directly or indirectly, the failure model of organization and prevention.
The discovery of the breach occurs internally, by the company itself, and the offender is punished immediately, without tolerance cases occur.
Zero tolerance applies to all compliances, both to subordinates and to managers.

In conclusion, reporting channels or ethical lines and the companies that have them, benefit in many ways that are positive their productivity, reputation and market competitiveness.




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The key factor employees used to discover Corporate Fraud

Las Provincias Newspaper :: 22-10-2012



More and more companies have formulas, internal or external, to avoid diversion of funds and other deceptions.
stopWith the crisis onset, financial scandals erupted. They affected the banking sector, controlling organisms and business elites of some of the world's leading companies. Bernard Madoff topped the list, with a financial fraud of 50,000 million dollars, the largest in history, but followed by Jerome Kerviel from Société Générale; Alexis Stenfors from Merrill Lynch; Evon Dooley, of MF Global. They are names that have already passed into history of bad business arts.
However, far from abating the storm, we have breakfast each day with a new scandal. Social protests that ignite Madrid’s, Athens’ and New York’s streets point the finger at the 'immorality' of the financial class and business schools inject the transparency antidote in its programs for executives. Talking about business ethics is fashionable, but apparently is not practiced with the desirable assiduity.

«Without doubt, the current economic crisis is causing increasing fraud cases», says Gertrudis Alarcon, general director of the anti-fraud consulting GAT INTELLIGENCE.

Diverting company funds with improper charges for expenses assumptions, counterfeit bills, personal purchases with business cards, fictitious expenses on business trips, nonexistent purchases, theft of company property or collection of fees to suppliers are the most common frauds.
José Manuel Muries, president of the Institute of Internal Auditors does not believe, however, that the crisis has favored unethical behavior. «I’d rather believe that, conversely, we are immersed in this crisis because in many cases there hasn’t been any action, with the entire ethical or professional rigor that you would expect».
A report by the ACFE- a professionals’ worldwide organization specialized in the fight against fraud reveals some disturbing figures; businesses lose each year 5% of their income due to internal fraud, nearly half of the Spanish companies acknowledge have been affected in the last year for incidents involving economic crimes, and between 6 and 8% of employees would be willing to commit fraud in their company if they found the opportunity.
Gertrudis Alarcon warns that all these practices are impacting negatively on the economy. «The crisis itself is making employers, and even consumers not to claim the bill for rendered services or purchased products, to lower their expectations of what is purchased with less quality assets and produced exchange of services for each other without consideration».

Vigilant Workers
According to the ACFE report, most corporate frauds are discovered by employees themselves. «People who live daily with the employee who is committing fraud are in the best position to notice changes in habits, unusual attitudes, unusual requests to perform certain tasks or excessive interest in dealing personally with some matter without leaving others to intervene», Gertrudis Alarcon says.
Sometimes, committing fraud within a company requires the participation of other employees, but the expert warns that this participation, in most cases, is involuntary; often they do not know that a fraud is being committed. Of course, over time they can begin to suspect that something is not right and the ideal moment to tell what happens presents itself. «Connivance between several employees to commit fraud in a company is not common, but it also occurs» Alarcon says. In general, workers often use letters by postal mail, 'e-mails', personal interviews or 'on-line' channels to report to senior management that something happens.
The solution, the director of GAT INTELLIGENCE says, has to do with «dissuasive measures, intensifying the struggle against fraud, raising awareness campaigns and a less burden tax system which do not compensates committing any fraud», Gertrudis Alarcon says.

Indeed, the company has launched the business ethics service line in Spain, a complaint and identification of inappropriate behavior mechanism. It is a safe confidential complaints mechanism, integrated into an 'on-line' platform. The service consists of a website where employees and related parties may denounce irregularities in writing. This page has a certified secure server and the connection is made with a protocol that allows data encryption between the browser and the server. The company states that this complaint mechanism reduces by 50% the fraud average loss.
José Manuel Muries, president of the Institute of Internal Auditors, believes that the figure of the internal auditor has become «essential» during these times. «We are a mix between journalists and doctors: we ask questions to understand how the organization works – we analyze facts - and where appropriate, we recommend a treatment (recommendations)». This is a figure whose role is to oversee that the organization has properly managed risks and, therefore, may be essential in the company’s ethical strategy.
Muries calls internal auditors to defend the profession’s values - ethics, objectivity and professional rigor – and recalls that «above all, they must be independent». Indeed, the independent vice president of Bolsas y Mercados Españoles (Spain’s Stock Markets and Sales Market), Margarita Prat, was very clear as regards this issue in a recently organized conference by the Institute of Independent Auditors. «The one who does not feel supported by their company should not continue in their position».

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