44 replies to this topic

[Martinblue]

Hi, Have anyone got generic procedure for confidential reporting system to share. Appreciate your support. Thanks Martin

[lmacfarland]

We do not have a procedure but once active will be posted on the employee boards for all to know where to report to.

 

Is a written procedure needed for this? 

[Martinblue]

I would say so. Having some sort of written statement could also work which could be explained to auditor.

[Leila Burin]

Hello,

check the Interpretation Guide, the "example": "The auditor sees a ‘whistleblowing’ policy which states that concerns can be reported using an online web

form or telephone number, the content of which is collated and submied to the production manager, technical manager and external consultant."

 

You can writte a work instruction also....

best regards,

Leila

[QSDA]

Hi Martin

Is the attached any good, bit wordy but should satisfy auditor

 

 

[QSDA]

sorry no file

Attached Files

•  1.05 POL Company Whistleblowing Policy (1).docx   44.98KB   1054 downloads

[ilonar]

Hello Martin,

 

We don't have yet a written procedure, but I attended a workshop on BRC v8 and I can tell what we were told there. the idea behind this requirement is that an employee sees that activities within the company are not complying with the written procedures/instructions and there might be a risk involved for the final product. He can't confront his colleagues/superior because they will not change the way they are working, but he also doesn't want to report it to the Management because he is afraid that in the end the ones that are comiting something wrong will take "revenge" on him. That is why he should get the chance to report it anonymously. We got the suggestion to use an old mobile phone from the very old generation and by a prepaid card for it and set it that the calling number is anonymous. Give the phone randomly  to employees from the Management, so that nobody knows who will pick up the phone. I find that this will not work within our company because of the language barrier (Dutch-English-Polish-Romanian-Hungarian), but also because you can recognise the voice. what I was thinking is to create a yahoo/gmail account, give the password to all employees and tell them that they can send their concerns to the email address of the secretary (who is a HACCP member) and who will assess the complaints that are received. Also, during the management review, the anonymous reporting system has to be assessed: you discuss how many reports you received, how you dealed with them. The auditor will check a few of them or the reporting system in case there are no reported concerns.

 

I hope that my explanation is useful for you or other members of the group. If someone has better ideas or thinks that it is not entirely ok what I wrote, I don't mind hearing other opinions that can improve the way we consider this point can be implemented.     

[Scampi]

For me, it's always been included in new employee orientation as well as annual refresher. The employees can always go to a HACCP team member who will not share the employees ID,but will ensure the matter gets addressed

[Jeff M]

Hi, Have anyone got generic procedure for confidential reporting system to share. Appreciate your support. Thanks Martin

 Hello Martin,

 

I had my HR Manager add a section to the open door policy of the employee handbook that states the phone and extension to call in any food safety concerns.  Once the handbook is finished, I will post the notice at every timeclock.

[Jeff M]

Hello Martin,

 

We don't have yet a written procedure, but I attended a workshop on BRC v8 and I can tell what we were told there. the idea behind this requirement is that an employee sees that activities within the company are not complying with the written procedures/instructions and there might be a risk involved for the final product. He can't confront his colleagues/superior because they will not change the way they are working, but he also doesn't want to report it to the Management because he is afraid that in the end the ones that are comiting something wrong will take "revenge" on him. That is why he should get the chance to report it anonymously. We got the suggestion to use an old mobile phone from the very old generation and by a prepaid card for it and set it that the calling number is anonymous. Give the phone randomly  to employees from the Management, so that nobody knows who will pick up the phone. I find that this will not work within our company because of the language barrier (Dutch-English-Polish-Romanian-Hungarian), but also because you can recognise the voice. what I was thinking is to create a yahoo/gmail account, give the password to all employees and tell them that they can send their concerns to the email address of the secretary (who is a HACCP member) and who will assess the complaints that are received. Also, during the management review, the anonymous reporting system has to be assessed: you discuss how many reports you received, how you dealed with them. The auditor will check a few of them or the reporting system in case there are no reported concerns.

 

I hope that my explanation is useful for you or other members of the group. If someone has better ideas or thinks that it is not entirely ok what I wrote, I don't mind hearing other opinions that can improve the way we consider this point can be implemented.     

 

Those are great ideas!  I like the email or text idea.  I am just going to post the QS number and extension, I do not know if that will suffice?

[QALab1438]

We are such a small company and was thinking about doing a suggestion box for anonymous reporting - has anyone use this before?  

[LSB]

We are such a small company and was thinking about doing a suggestion box for anonymous reporting - has anyone use this before?  

We use a suggestion box, but make sure it is out of view of any cameras that you may have at your facility. It has been relatively successful other than people writing just to write. a thorough investigation needs to be completed on complaints to ensure they are not fabricated from a disgruntled employee....

Best practice would to have a generic complaint form that way you can weed out the non relevant issues that would then muddy the water on corrective action and what the auditor might ask to see. IMO

[Franny]

osted 06 March 2019 - 02:03 PM

We are such a small company and was thinking about doing a suggestion box for anonymous reporting - has anyone use this before?  

 

Yes as a small company also, that's what we will be doing. Suggestion box situated where it isn't in a line of view. The only problem I can see with this is, what if no-one uses it? The employees here have always been comfortable face-to-face with supervisors.

[LSB]

My suggestion would be to have a designated member that is not involved with senior management (I.E. an assistant supervisor, or HR if you have the staff)  to be the delegate for employees to voice their concerns.

This delegate would then write the complaint down, the date, but not the name of the employee; and then compile the list on a frequency of your choosing....probably monthly or at the same frequency of your internal audits. I do not think taking complaints in that manner would be a problem, as long as everything stays anonymous.

[ilonar]

We are also a small company and it is very comon that comunication just happens face to face, but according to BRC it should be confidential and annonimous (this is a word used in the implementation guideline). I put in our canteen (the place where for sure all employees go), in the most used 4 languages a paper with the following information:

 

"If you have any questions, ideas of improvement or concerns regarding food safety, integrity, quality and legality, do not hesitate to contact the members of our HACCP team: X, Y, Z (their names. BRC has a requirement that the members of the HACCP team have to be known within the company. So this requirement is ticked off)

 

In case you would like to do this anonymously, go to (webpage with email address) and log in using:

username: xxxx

password:xxxx

 

Send an email to the addresses (my email address) and (the one of the secretary, also HACCP team member) in which you can write down your concern or idea of improvement. We will analyse it and see what measures we have to take. "

 

 

Additionally, in the hygiene rules they are informed about the confidential reporting system. 

 

During the monthly HACCP meeting and the annual management review, the received emails and the actions will be discussed. Even if nothing is received, it will still be noted. 

[QM-OS]

I don't understand how a phone call/voice message can be considered anonymous?

 

We have ended up with suggestion boxes and paper forms. Employees fill in and they can chose to report issues anonymously or sign with their name.

[LSB]

my question for everyone is how are you deciding what is relevant and not relevant.

Are people putting food safety concerns? or are they putting a multitude of other various plant issues?

Are you only putting food safety related concerns on the corrective actions?

[aab93]

my question for everyone is how are you deciding what is relevant and not relevant.

Are people putting food safety concerns? or are they putting a multitude of other various plant issues?

Are you only putting food safety related concerns on the corrective actions?

 

I agree - last week our HR Coordinator held a meeting to cover sexual harassment and, when she presented the Anonymous Complaint Form, she suggested that it be used as a platform to report those things... not exactly what I originally had in mind when I presented the idea to my facility's senior management.

 

Nevertheless, I figured that determining relevancy and urgency to address the complaint could be based on risk - IE; a matter involving someone not following practices and/or directions that could potentially affect food safety would be heightened, while personnel-to-personnel matters be addressed accordingly. These are just my thoughts

[pHruit]

I don't see a problem with a multi-purpose reporting system - ours covers food safety, HR issues, financial integrity issues, modern slavery etc.

You just need to have a process in place to assess each report to determine an appropriate course of action, and you'd need to be doing this anyway.
I don't think telling staff that they can only report specific types of issue would be very positive?

In theory I think the ability to raise legitimate concerns about any area should be encouraged.

 

As for anonymity - it's pretty much impossible these days:
Phone - recognise voice

Handwritten paper forms - recognise handwriting

Electronic form that you fill in on the computer and print - most larger printers will have a log of who has printed what

Web portal - IP address log

 

All you can therefore reasonably endeavour to do is be aware of the potential pitfalls so that they can't be abused, IMO.

[LSB]

Just for clarification.....I was not implying that you tell staff what they can and cannot report. You would decide what is included in corrective actions and what is on the report. The way i have tentatively set up our whistleblower program is in conjunction with our current safety suggestion box. The anonymity is obviously the toughest thing. If you have a clearly defined senior management list and depending on how big your plant is, i think you can easily make it to where supervisors or leads are the preferred route for relevant complaints. They could simply write them down and then later be transcribed anonymously to whatever controlled form you might use.  

[S-S]

I was also thinking of a box in our staff lunch room.

 

I'm trying to elaborate a form. I was wondering if on the form the employee have to write is name ?

 

Do you let them the choice to write their name or not or is it mandatory they state their name?

Thank you

[ilonar]

The implementation guideline from BRC says "anonymously", so it should be without name.

[pHruit]

I'd give the option of adding a name, but make it clear that it is optional - there may be people who want to be able to discuss the follow-up to what they've raised.

[zanorias]

I don't ask for name, however if someone wants to write their name on top (as people have) that's up to them, though it needs bearing in mind that we can't assume 100% the paper belongs to that person i.e. someone might think it's funny to fabricate something, write their colleagues name on it and pop it in the box.

 

Similar to others, I use a number of small post boxes fixed around the site in changing rooms where there are no cameras, and the boxes can only be unlocked and emptied by a small number of specific staff. Employees are encouraged to use the boxes for any reporting purpose they deem necessary. I'd rather have to sift out irrelevant or joke ones than staff feel they may not be able to report something because it doesn't fall under a certain category,

 

Keeping communication 100% anonamous will be difficult as pHruit mentioned, though still best to provide the option to employees. We ask staff to complete a food safety culture questionnaire also and post this in the boxes. It has 10 questions with circling 1-5 required for answers so it's pretty much impossible to tell who has completed it, and it provides a good overview of general views in data that can easily be analysed. The questionnaire has boxes for department and classification (line operative/supervisor etc) but this is optional.

[LSB]

Whistleblower Policy

 

*************** requires managers, supervisors and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and

representatives ******************* we must practice honesty and integrity in fulfilling our

responsibilities and comply with all applicable laws and regulations.

 

Reporting Responsibility

This Whistleblower Policy is intended to encourage and enable employees and others to raise

serious concerns internally so that ***************** can address and correct inappropriate

conduct and actions. It is the responsibility of all persons employed by *********************

to report concerns about violations of our pre-requisite programs, safety, and food safety.

 

No Retaliation

It is contrary to the values of *****************  for anyone to retaliate against any individual who in good faith reports a violation, or a suspected violation, (i.e complaint of discrimination, or suspected fraud, or suspected violation of any pre-requisite programs of the operations of ******************. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

 

Reporting Procedure

*****************  has an open-door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor, or the human resources department. Verbal complaints are accepted in the Human Resource office, and the identity of the employee shall be kept confidential. Also, supervisors are required to report complaints or concerns about suspected violations listed above in writing to who has the responsibility to investigate all relevant reported complaints. Employees with concerns or complaints may also submit their concerns in writing directly to the suggestion box located in the break area or in the Human Resource Office.  Senior management is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved.

 

Acting in Good Faith

Anyone filing a written complaint concerning a violation or suspected violation must be acting in good

faith and have reasonable grounds for believing the information disclosed indicates a violation. Any

allegations that prove not to be substantiated and which prove to have been made maliciously or

knowingly to be false will be viewed as a serious disciplinary offense.

 

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant.

Reports of violations or suspected violations will be kept confidential.

 

Handling of Reported Violations

All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the complaint or investigation of complaint.

 

This is the exact program i have implemented at our facility. Took a little bit to make/modify.....let me know your thoughts. This might be able to help someone out. Feel free to use at your own risk!