SilentWhistle

SilentWhistle SOX Legal Fulfillment

Operator Qualifications
All hotline operators are college-educated, full-time salaried professionals with full health, dental and retirement benefits. They are chosen based upon academic achievement, writing abilities, past job performance and demonstrated ability to handle the requirements of the position. Their qualifications are verified, and they are then asked to provide writing samples under conditions designed to replicate those of a hotline call. Successful candidates sign a confidentiality agreement
and are hired on a three-month probationary basis.

Operator Training
It is required that operators undergo a three-week training program designed to teach them how to interview callers and obtain the information necessary for a thorough investigation. Training begins with computer-based orientation and training programs for hotlines and compliance programs. Two software programs are used for this general orientation schedule. The first is an interactive A-to-Z desktop reference tool that provides trainees with an introduction to hotline operations. Through a series of modules, trainees are briefed on various aspects of hotline operations such as protecting caller anonymity and confidentiality, report generation, file maintenance, call answering and debriefing techniques. The program also offers a tutorial to lead trainees through difficult problem-solving and improve their knowledge of hotline operations and interviewing skills. Checklists are included for each module to highlight key points for trainees.

Second Phase of Training
A second level of training includes a study of sample hotline calls and issues. Trainees are asked to identify the key issues in each sample call and describe how they would elicit the information necessary to allow effective investigation. For the second phase of training, each trainee shadows a senior operator, monitoring calls taken by the senior operator. The trainee and the senior operator discuss the issues raised by the caller. The trainee is encouraged to ask questions about any matters that are unclear.

Test Calls
We surprise each new employee with test calls to ensure that the hotline operator is capable of handling whatever situation may arise. Test calls present atypical problems so management can judge the operator’s ability to “think on his/her feet.” Interpersonal communication, phone demeanor, computer skills and the ability to work effectively in a multi-stimulus environment are also honed and refined.

Expectations of Trained Operators
Once fully trained, all hotline operators are expected to:

• Properly interview callers, obtain all relevant information and follow each client’s individual protocols for handling calls.
• Ensure that all information given by the caller is accurately reported. (Hotline operators will make no judgments about the accuracy of information.)
• Treat all callers with respect.
• Recognize terminology, acronyms and abbreviations common to the caller’s workplace.
• Demonstrate professionalism to all callers.
• Demonstrate problem-solving abilities and aid compliance, human resources and other personnel when assistance is requested.
• Protect the anonymity of those who call the hotline, unless the caller desires otherwise.
• Protect the confidentiality of matters brought to the hotline, sharing information only with those with a legitimate “need to know.”

Hotline operators are evaluated on a quarterly basis, and the Chief Operating Officer addresses any deficiencies in their performance. All operators attend mandatory enhancement seminars to keep them abreast of significant changes in compliance and corporate rules, regulations and policies. Hotline operators also undergo ongoing refresher sessions with senior operators to ensure continued excellence in job performance. The ratio of executive and supervisory personnel to operator staff is 1:2.