9. Openness

A holistic approach to public integrity includes measures aimed at fostering openness, in which public officials feel safe actively identifying, raising questions, concerns or ideas, and responding to potential violations of public integrity. Building an open organisational culture has three main benefits: first, it can build trust in the organisation; second, it can cultivate pride of ownership and motivation, thereby increasing efficiency (Martins and Terblanche, 2003[1]); and third, in an open organisational culture anyone can raise questions to resolve them before they become damaging to the organisation. Open communication and commitment to organisational values creates a safe and encouraging environment where employees voice their opinions and feel comfortable freely discussing ethical dilemmas, potential conflict-of-interest situations, and other integrity concerns.

The OECD Recommendation on Public Integrity calls on adherents to “support an open organisational culture within the public sector responsive to integrity concerns, in particular through:

  1. a. Encouraging an open culture where ethical dilemmas, public integrity concerns, and errors can be discussed freely, and where appropriate, with employee representatives, and where leadership is responsive and committed to providing timely advice and resolving relevant issues;

  2. b. Providing clear rules and procedures for reporting suspected violations of integrity standards, and ensure, in accordance with fundamental principles of domestic law, protection in law and practice against all types of unjustified treatments as a result of reporting in good faith and on reasonable grounds;

  3. c. Providing alternative channels for reporting suspected violations of integrity standards, including when appropriate the possibility of confidentially reporting to a body with the mandate and capacity to conduct an independent investigation” (OECD, 2017[2]).

Within the context of public integrity, an open organisational culture means employees, managers and leaders can regularly engage in conversation with the aim of raising questions, concerns or ideas and preventing misconduct, fraud or corruption (Detert and Edmondson, 2011[3]; Morrison, 2014[4]; Collins, 2012[5]). This is complemented by formal reporting mechanisms, such as whistleblowing and other internal disclosure policies, which enable employees to report misconduct through an official channel when the misconduct has already taken place. An open organisational culture has the following supportive elements: leadership that is responsive and committed to providing timely advice and resolving relevant issues; and employees who are comfortable raising ethical concerns (OECD, 2017[2]). Achieving these two elements involves the following:

  • Public officials identify with the organisation’s values.

  • Public officials are engaged and empowered to safeguard their workplace values.

  • Leaders and managers are responsive, credible and trustworthy on integrity issues and concerns.

  • Safe environments for voicing questions, concerns and ideas are cultivated and sustained.

  • Channels and mechanisms are established to ensure misconduct is reported, investigated and appropriately sanctioned, and whistleblowers feel protected and comfortable voicing concerns.

A key element for ensuring openness requires public officials who identify with the purpose of the organisation, know the rules and procedures, and understand how they are implemented in practice. When organisational values and norms conflict with those of the employee, their commitment and involvement to the organisation will likely suffer. On the one hand, if employees hold their personal values to a higher standard than the organisation, they will experience a conflict, resulting in decreased commitment and unwillingness to speak up against potential wrongdoing (Berry, 2004[6]). On the other hand, if an employee’s personal integrity standards are lower than those of the organisation, then integrity breaches run the risk of being viewed as a necessary part of daily routine (Berry, 2004[6]).

Concrete practices to cultivate identification with the values include communicating rules and standards in plain language (for more, see Chapter 4) and hiring on ethical fit (for more, see Chapter 7). Organisations could also ensure that when new employees are brought on board, training includes discussions about the rules, standards and values of the organisation (for more, see Chapter 8). Other tools could include an integrity awards system, whereby employees can nominate their peers based on their demonstration of the organisation’s values (Box 9.1).

To cultivate identity with the organisation’s values, the Whistleblowers Authority in the Netherlands suggests using a “joint storytelling” method. This includes leaders and managers asking questions like, “What is important to us, what do we value and what are we proud of?” – and, together with employees, talking about the organisation, its history, the common future and how they want to achieve this. The underlying rationale is that through sharing stories, everyone gains more insight into the existing culture. It creates a bond and cohesion between people and work, and can contribute to a safe environment within the organisation (Hoekstra, Talsma and Zweegers, 2017[8]).

An employee whose voice is heard is more likely to feel engaged when speaking up to constructively address a problem (Holland, Cooper and Sheehan, 2017[9]; Beugré, 2010[10]; LePine and Van Dyne, 1998[11]). Engagement and openness are also mutually supportive, with open organisational cultures enhancing engagement. Indeed, when employees perceive opportunities to genuinely voice their concerns and participate in decision making, employee engagement improves (Beugré, 2010[10]).

A number of tools exist to build employee engagement and empowerment. For example, employees whose managers consult them one-on-one have a positive view of their individual influence on their work surroundings (Tangirala and Ramanujam, 2012[12]). This in turn can impact their willingness to engage and voice ideas or concerns. Leaders can also practice “leaning out” so that employees can “lean in”, such as changing where leaders sit/stand (e.g. at the middle of the table rather than at the head) or the order of interventions to ensure that staff speak first or are given speaking time in meetings (Tilleard, 2018[13]).

Mechanisms should not focus solely on improving one-on-one engagement between managers and employees. Leaders may want to consider establishing group spaces to facilitate feedback, making opportunities available for those who do not feel comfortable speaking up in a one-on-one situation. These spaces could take the form of regular meetings, where the team knows in advance that issues, problems and potential solutions can be raised, or ad hoc meetings when specific issues arise. Leaders may want to thank and publicly acknowledge employees who speak up during these meetings, as well as adopt at least one idea or solve one problem mentioned, demonstrating that speaking up has results (Detert and Burris, 2016[14]). Other options may include using online tools to elucidate feedback, such as the ThinkGroup process developed by the United Kingdom Behavioural Insights Team (Box 9.2).

Another possible tool is selection of “Openness Champions” who would consult staff on measures to improve work processes, well-being and general openness. The Champions could be responsible for facilitating feedback on certain issues, or assigned to specific units or directorates. Their purpose would be to identify key hotspots within the organisation that require change, or where good practices for supporting openness exist.

An employee’s willingness to speak up relates positively to perceptions that managers and leaders are transformational and ethical leaders (Avey, Wernsing and Palanski, 2012[16]; Detert and Burris, 2007[17]; Walumbwa and Schaubroeck, 2009[18]). A number of tools exist to support leaders in demonstrating their commitment to integrity, including recruitment and performance systems that include integrity, role modelling, communicating about integrity, rewarding good behaviour and sanctioning poor behaviour (for more, see Chapter 6). Other tools such as guidelines can be developed to support managers in taking concrete actions to create an open workplace (Box 9.3).

While leaders who “walk the talk” are critical to fostering trust, managers who show candour with their own management can also cultivate credibility and trust. In other words, managers who speak up to their leadership on behalf of the concerns voiced by their employees demonstrate that they can be trusted (Knight, 2014[20]; Detert and Burris, 2016[14]). Indeed, a manager’s willingness to “run issues up the food chain” improves employees’ willingness to come forward to the manager in the first place (Knight, 2014[20]). While managers and leaders can capitalise on opportunities to raise issues with their management in front of employees, there are times when this will not be feasible. Leaders and managers can debrief employees’ on what they discussed and what next steps (if any) are required. Doing so has three main benefits: i) it demonstrates to employees that managers are willing to speak up on their behalf; ii) it broadens employees’ perspectives on the barriers leaders face; and iii) it keeps employees informed about progress, thereby eliminating feelings of futility (Detert and Burris, 2016[14]).

“Psychological safety” or a safe environment is a baseline condition for openness within an organisation (Liang, Farh and Farh, 2012[21]). When making a decision about whether to speak up, employees will first assess whether it is safe to do so (Dutton et al., 2002[22]). Indeed, a key deterrent to an open organisational culture is an environment where employees fear their ideas, insights and observations will be rejected, or more worryingly, that speaking up will lead to penalties.

There are a number of practical ways to cultivate and sustain a safe environment. For example, leaders and managers could acknowledge errors and turn negatives into lessons learned for future projects. Publicly discussing what went wrong, and what can be done differently, can strengthen employees’ courage to seek advice. At the core, leaders and managers should be open to suggestions and consistent in encouraging diverging views, as well as not retaliating when their own views are threatened (Saunders et al., 1992[23]).

Other options include moving beyond the “open door” policy, and speaking to employees in less formal settings, such as over a coffee or lunch. Evidence has found that an open door policy rarely achieves the desired effect of creating more openness, as it still enforces a power dynamic that is difficult to overcome (Detert and Treviño, 2010[24]). Other approaches include making leaders more accessible to employees at all levels. For example, in Victoria, Australia a “reverse mentoring” programme was piloted by the Public Sector Innovation Team: senior executives were matched with more junior staff, with the objective of learning from them and taking in different perspectives. Another solution is to implement 360-degree feedback processes that allow employees to provide feedback on their managers, as well as their skip-level leaders (that is, the manager two or three levels above them). The information can help the organisation identify the links in the upward communication chain that require repair and target resources for training accordingly (Detert and Treviño, 2010[24]).

Even in very open organisations, public officials may be faced with situations in which they do not feel confident reporting integrity violations to their manager. As such, establishing a clear and comprehensive whistleblower protection framework is a critical component of an open organisational culture. A robust whistleblower protection system starts with clear and effective communication. Informing both employers and employees about their rights and responsibilities and the resources available to them is crucial for fostering an environment of trust, professionalism and collegiality that supports integrity.

The following features are essential components of whistleblower protection policies that public sector entities should seek to establish to strengthen an open organisational culture:

  • clear reporting channels

  • prohibition of formal and informal work-related sanctions

  • clear types of protection guaranteed

  • effective reviews and investigation of complaints

  • awareness-raising measures.

Clearly defining channels of disclosure helps facilitate reporting, as otherwise whistleblowers may lack confidence in the system or may not be comfortable coming forward. Reporting channels generally include internal disclosures, external disclosures to a designated body, and external disclosures to the public or to the media (OECD, 2016[25]).

Offering access to both internal and external channels creates an enabling environment for reporting. Internal disclosure is encouraged to strengthen an open organisational culture; it provides relevant information to responsible functions and contributes to an early and effective resolution of cases or concerns. However, depending on the situation, whistleblowers may prefer to report externally. Requiring that reports must first be made internally may discourage individuals from voicing concerns or reporting misconduct.

To avoid confusing procedures, the disclosure process should be accompanied by an explanation of the steps to follow and the processes to abide by in order to ensure that whistleblowers are well informed not only about whom to disclose to, but also about the potential repercussions of disclosing. For example, the Whistleblowers Authority in the Netherlands has developed guidance to clarify and facilitate both the design of reporting procedures and their implementation (Box 9.4) (Whistleblowers Authority, 2017[26]).

While the institutional arrangements of the whistleblower system depend on the country context, some countries use an external body with a defined mandate and adequate resources and capacities to receive complaints and conduct independent investigations on the misconduct reported. In Canada, the Office of the Public Sector Integrity Commissioner (PSIC) is in charge of investigations and resolutions of complaints. The PSIC is an independent body reporting, notably on its investigations, to Parliament only; with jurisdiction over nearly all federal government organisations, it is directly accessible to Canadian federal public servants for guidance or disclosure (Sulzner, 2009[27]). Summaries of cases investigated by the Commissioner’s office and subsequently set before Parliament are made publicly available on its website (PSIC, 2018[28]).

The absence of effective protection for whistleblowers can pose a dilemma, as employees are often expected to report wrongdoing but doing so can expose them to retaliation. Retaliation for whistleblowing usually takes the form of disciplinary action or harassment in the workplace. Therefore, whistleblower protection should provide comprehensive protection against discriminatory or retaliatory personnel action as well as against other behaviours such as exclusion, hostility and any form of harassment from managers and co-workers. Specifically, this could include protection from dismissal, suspension or demotion; transfer or reassignment; reduction of pay, benefits, education or training; and medical testing or examination (OECD, 2016[25]).

When a whistleblower has experienced reprisal after disclosing misconduct, providing clarity on the measures and remedies available can further reassure potential whistleblowers to come forward. A comprehensive whistleblower protection system includes specific remedies and covers all direct, indirect, and future consequences of reprisal. Remedies range from return to employment after unfair termination, job transfers or compensation, to damages if there was harm that cannot be remedied by injunctions, such as difficulty in or the impossibility of finding a new job. Such remedies may take into account not only lost salary but also compensatory damages for suffering (Banisar, 2011[29]).

Protecting the confidentiality of public officials who report within their organisation or externally to law enforcement agencies, the media or a civil society organisation is also essential (OECD, 2017[30]). In the United States, the whistleblower protection system prohibits disclosure of identifying information of a federal sector whistleblower without consent, unless the Office of the Special Counsel (OSC) rules it is necessary because of an imminent danger to public health or safety. In these cases, the whistleblower is informed in advance. The whistleblower protection system in Australia allows anonymity as one of three options for reporting a public interest disclosure (OECD, 2016[25]).

Legislating and implementing clear investigative procedures and timely responses to reports strengthen the credibility of the mechanisms. Managers’ responses to individual reports are a first step, ensuring the concern is addressed and misconduct or wrongdoings, when they are ascertained, are sanctioned. Additionally, in an organisational learning dynamic, when managers receive several complaints about similar situations, their overall response to adapt the system or process in place signals the impact of reports and strengthens the open organisational culture of the workplace. In its 2017-18 annual report, the PSIC of Canada emphasised such a systemic approach in three wrongdoing cases, focusing attention on working conditions of Canadian federal employees and on the responsibility to provide them with safe working environments (PSIC, 2018[31]).

As mentioned above, in addition to the responses given by managers and leaders, publishing the number and nature of cases contributes to transparency and the credibility of the reporting system. Bodies and units intending to make public such information can use a number of measures. For example, the US Office of Special Counsel publishes annual activity reports that detail the number of disclosures, the number of investigations launched or whom they were referred to, and a summary of cases with the investigations’ outcomes. These reports also include an analysis of systemic issues and responses when appropriate, as well as the processing time and the number of disclosures processed and closed, with comparative data from previous fiscal years (US Office of Special Counsel, 2018[32]). Publishing this information highlights the value given to voicing concerns in the workplace, and reinforces the knowledge that reports are investigated and misconduct addressed, in turn strengthening trust in the overall reporting and complaints-handling system.

A clear and comprehensive whistleblower protection framework also includes raising awareness about the channels and protections available. Efforts to raise awareness through campaigns or training in the types of protection available and the provisions in place to prevent retaliation can reassure employees that disclosures are welcome and part of their professional duty. Some countries, such as the Slovak Republic, have integrated whistleblower protection into their ethics training, forging a strong link between protecting the public interest and integrity. Similarly, the No-FEAR Act in the United States requires that agencies provide annual notices and biannual training to federal employees regarding their rights under employment discrimination and whistleblower laws.

Although challenges may vary depending on the local and national contexts where organisations operate, a few common ones may deter governments from effectively implementing open organisational cultures. The most relevant of these, discussed below, are:

  • addressing hierarchical, formal civil service cultures

  • building capacity and dedicating resources

  • ensuring comprehensive and clear protection

  • shifting the negative connotations associated with whistleblowing

  • creating safe environments through confidential or anonymous reporting.

A core feature of many governments is a hierarchical and formal culture that operates on a basis of “deference to superiors” (Mulgan, 2000[33]). Various chains of command are in place, with lines of authority and accountability to ensure effective policy making and service delivery. The purpose of hierarchy is twofold: to ensure greater clarity and to provide greater sanctioning authority (Jarvis, 2014[34]). Hierarchy can, however, have a chilling effect on openness.

Addressing this within the parameters of a formal structure is challenging, and requires every level to implement actions to improve openness. The necessity for leaders to act consistently with the organisation’s values, as discussed in Section ‎9.2.3, cannot be overstated in a hierarchical organisation. The primary focus within such environments, however, should be on the immediate team, where managers implement measures to engage and empower their employees and ensure a safe environment. Practical measures can include holding regular team meetings to discuss issues, organising informal events, placing boxes in the workplace to collect complaints, feedback and ideas, and ensuring regular feedback mechanisms for employees are in place. Managers can also implement the practice of bringing concerns to upper management and communicating the results back to their employees, as discussed in Section ‎9.2.3. Regular open discussions and feedback can also reduce the gap that hierarchical formalism may create between leaders, managers and their employees.

Lack of capacity and resources is often a main reason for slow or limited implementation of the established channels and framework. This may in turn lead individuals to believe that their complaints or reports will not be assessed, causing an additional loss of trust in the system. Moreover, a lack of resources, guidance and knowledge on how to create open and safe environments may result in even greater loss of trust and employee silence.

Organisations can strengthen both an open organisational culture and an effective whistleblower protection scheme by dedicating human and financial resources to these aspects. Capacity-building opportunities are an additional element to help managers better understand and diffuse an open culture in their team, and to increase effectiveness of whistleblowing schemes by supporting and providing dedicated staff with updated knowledge and tools (for more, see Chapter 8).

While the majority of OECD countries have established whistleblower protection mechanisms, provisions throughout different pieces of legislation remain the norm. This can result in less comprehensive protection, with different actors and procedures for disclosure and distinct remedies. Moreover, such laws do not always cover the reporting of all forms of misconduct. Clear and comprehensive whistleblower protection laws can elucidate the disclosure processes and remedies for victims of retaliation (OECD, 2016[25]).

The lack of standardised procedures can also make it harder to report misconduct, and the reports may not be assessed consistently across different public organisations. Establishing clear procedures and channels, practical guidelines and standardising practices for referring reports to judicial authorities is essential to ensure consistent and effective whistleblower protection, as is co-ordination among detection and reporting mechanisms to avoid overlaps or duplication.

The terms “whistleblowing” or “whistleblowers” can be associated with snitching or disloyalty to the organisation or country. Addressing these perceptions is essential to encourage public officials with concerns or information to come forward. Some countries have chosen to use a term that is more appropriate to the culture and role of bringing concerns forward. For example, in Dutch, the term used is klokkenluider or bell-ringer, which calls to mind those who in the past rang the bell to signal impending danger to the community.

Awareness-raising campaigns can also highlight the role of whistleblowers in safeguarding the public interest. Such campaigns can change the negative perceptions, both within and outside public organisations, that blowing the whistle is a lack of loyalty to the organisation. For example, the UK Civil Service Commission includes a statement in staff manuals to reassure staff that it is safe to raise concerns. In the province of Alberta, Canada, the Public Interest Commission designed a series of posters and distributed them to public entities. The posters show messages such as “Make a change by making a call. Be a hero for Alberta’s public interest”.

By expanding these communication efforts externally, the public perception of whistleblowers as important safeguards for the public interest can be improved. For example, in the United Kingdom the way the public understands the term “whistleblower” changed considerably since the adoption of the Public Interest Disclosure Act in 1998 (Box 9.5) (OECD, 2016[25]).

While whistleblower protection systems should ensure that the identity of the individual is kept confidential, several challenges exist. First, the identity of the whistleblower may be deduced from the report or circumstances described, especially in small organisations or small countries, making it difficult to provide adequate protection. Disciplinary provisions for breach of confidentiality requirements can help address this challenge. In Korea for example, disclosure of a whistleblower’s identity (or information helping to identify them) may be sanctioned by a three-year prison sentence or a fine of KRW 30 million.

Second, in cases where anonymous reporting is allowed, challenges can lie in following up on the information of the reporting person, or holding them accountable for false allegations. To balance this challenge the Ministry of Justice in Austria created an online portal for reporting, which allows for encrypted anonymous reporting and follow-up and feedback through a case numbering system (OECD, 2017[30]).


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