Best Practices for Strengthening Trust in the Ethics Channel

João Guilherme da Hora Costa; Bárbara Teles Araújo Silva

DOI: 10.22167/2675-6528-202603037

Article derived from a Final Course Work (TCC), with content based on the student’s original work and adapted to the editorial format of the E&S Magazine with the support of the ResumeAI tool, an artificial intelligence solution developed by the Pecege Institute for textual synthesis and organization.

Abstract

The ethics channel has consolidated itself as a relevant mechanism for identifying irregularities and misconduct within the organizational scope. However, despite its incentive and regulatory obligation, resistance to its use by stakeholders was observed. The study aimed to examine the main difficulties related to the implementation and operation of the channel, as well as to identify measures capable of mitigating these barriers and strengthening its credibility with internal and external audiences. The research was developed in two complementary stages: a theoretical phase, which analyzed specialized doctrine and applicable Brazilian legislation, and an empirical phase, which consisted of conducting semi-structured interviews with Compliance professionals. The results allowed for the identification of essential requirements for the proper functioning of the channel and highlighted best practices, such as clear institutional communication, continuous training, engagement of senior management, structured treatment flow, safeguards for the whistleblower, careful disclosure of results, and permanent monitoring. It was found that the most recurrent weaknesses stemmed from predominantly communicational factors, which can be mitigated by consistent and segmented acculturation strategies. It was concluded that trust in the ethics channel is structuring for its effectiveness, and the identified vulnerabilities can be substantially mitigated by strategic communication, contributing to a culture of integrity that values transparency and the technical treatment of irregularities.

Keywords: Credibility; Whistleblowing; Integrity; Stakeholders; Whistleblower.

1. Introduction

The recent Brazilian movement to encourage the adoption of a culture of integrity in the private sector has driven the creation and improvement of management systems aimed at preventing, detecting, and remediating irregularities, deviations, fraud, and other illicit acts in the corporate environment. In this scenario, the whistleblowing channel, widely known as the ethics channel, has consolidated itself as one of the main detective mechanisms, functioning as an institutional communication channel exclusively for reporting irregular conduct. The importance of this instrument is corroborated by data from the Association of Certified Fraud Examiners (2024), which indicate that 43% of identified corporate fraud originated from reports submitted through this channel, a percentage more than three times higher than that verified for the second most recurrent detection method.

The diffusion of this tool stems from practices developed in the United States, where whistleblowers are historically encouraged to report irregularities, either through financial rewards or by offering protection against potential retaliation (Veríssimo, 2017). García Moreno (2018) highlights that the “whistleblower” is usually a “stakeholder”, meaning a party with a direct link to the organization, which gives them greater knowledge of internal operations and access to sensitive information. With the evolution of integrity programs, ethics channels have become an institutional alternative for reporters, who previously turned to public authorities or the press, allowing organizations early access to irregularities and reducing the risk of unexpected external exposure.

From a normative perspective, the Brazilian legal system has recognized and legitimized the whistleblowing channel as a relevant component of integrity programs. This is evident from Decree No. 11,129/2022, which regulates Law No. 12,846/2013 (Anti-Corruption Law), and Decree No. 12,304/2024, which regulates Law No. 14,133/2021 (Law on Public Procurement and Administrative Contracts). Furthermore, Law No. 14,457/2022, by establishing the Emprega + Mulheres Program (Employ + Women Program), made the implementation of this instrument mandatory for business companies that have an Internal Commission for Accident and Harassment Prevention, with a view to preventing and combating sexual harassment and other forms of workplace violence.

Despite its relevance and legal support, the ethics channel may be perceived with distrust by “stakeholders”. García Moreno (2018) warns that when the integrity management system proves ineffective, the reporting mechanism tends to be directly impacted, resulting in its misuse or even inactivity. The reporter’s trust depends, above all, on the perception that they will be protected against potential retaliation, which makes the existence of clear and effective safeguards indispensable. The channel’s credibility is also affected when complaints are not treated seriously, when corrective measures are not adopted, or when the organization, especially its top management, does not demonstrate its explicit support. Additionally, doctrine highlights that stigmas associated with the act of reporting persist, with the reporter potentially being perceived by their peers in a pejorative way, as a “snitch” (Guillén Ortega, 2021; Espín, 2017), which requires reinforcing that the communication of irregularities occurs for the collective interest.

Given this panorama, it is perceived that, although essential for promoting integrity, the tool must be structured in a way that conveys security and credibility to organizational actors. The present work aims to identify and analyze the perceptions of experienced professionals in the area of compliance, regarding the main fragilities related to the implementation and operation of the ethics channel, as well as to present practices capable of mitigating them, contributing to the strengthening of the trust of the publics involved and, consequently, to its effective functioning.

2. Material and Methods

The present study was characterized as a qualitative research, with an exploratory and descriptive approach, seeking to deepen the understanding of trust in the ethics channel. The adopted methodology was designed to investigate a complex phenomenon, involving individuals’ subjective perceptions and experiences. The research was structured in two complementary stages, aiming for a comprehensive analysis of the topic. The first stage consisted of a theoretical phase, while the second comprised an empirical phase, both interconnected to provide an integrated view.

The theoretical phase was developed through bibliographic and documentary research. The bibliographic research was carried out using specialized literature in the area of Compliance, including books, manuals, and scientific articles. For the selection of materials, the Integrated Search Portal of the University of São Paulo (USP) was used, ensuring access to relevant and up-to-date academic sources. This stage allowed for the conceptual foundation of the study, exploring the main debates and concepts about the ethics channel and its credibility.

In parallel with the literature review, documentary research focused on applicable national legislation was conducted. Regulations such as Law No. 12.846/2013, Law No. 14.133/2021, Decree No. 11.129/2022, Law No. 14.457/2022, Decree No. 12.304/2024, and Normative Ordinance SE/CGU No. 226/2025 were analyzed. The documentary analysis was restricted to federal legislation, in accordance with the delimitation of the scope of the work, with the objective of identifying the normative framework that legitimizes and regulates the whistleblowing channel in Brazil.

The empirical phase consisted of data collection through semi-structured interviews. Due to the direct participation of human beings, the research project was submitted and approved by the Pecege Research Ethics Committee, under the Certificate of Presentation for Ethical Review (CAAE) No. 93777925.5.0000.9927. Five interviews were conducted with professionals working in the Compliance area, all with consolidated careers and recognized experience in private organizations established in Brazil.

The research participants were between 40 and 60 years old, with professional trajectories developed predominantly in the Southeast region of Brazil. Of the total interviewed, three were male and two were female. In observance of the principles of data minimization and proportionality, no information on ethnicity, sexual orientation, or religion was collected, as they were considered unnecessary for the study’s objectives and to mitigate the risk of identification. All participants were informed of the possibility of revealing their identity, but they opted to maintain anonymity.

The interviews were conducted using a previously developed script, which can be found in the appendix of this work. The script was adjusted according to the dialogue with each participant, allowing for the capture of perceptions, practical examples, and nuances relevant to the understanding of the phenomena studied. The interviews sought to identify the benefits of an effective reporting mechanism, the main challenges related to its structuring and implementation, the whistleblower’s expectations, and suggestions for good practices. The interviews were conducted and their transcripts were prepared using the videoconferencing platform “Zoom”.

The collected data were analyzed qualitatively, focusing on the identification, interpretation, and integration of the perceptions presented by the interviewees. The choice of a qualitative approach was justified by the nature of the study’s objective, which aimed to understand trust in the ethics channel, a phenomenon involving perceptions, experiences, and meanings that cannot be adequately measured by statistics. According to Prodanov and Freitas (2013), qualitative research allows for the exploration of the relationship between observed reality and individual subjectivity, with the interpretation of meanings attributed by participants being a central element of the investigation.

To assist in the process of systematizing the raw, fully anonymized data from the interviews, the artificial intelligence service “Microsoft Copilot” was used. This tool was also employed to translate scientific articles analyzed and to review the cohesion, coherence, and textual clarity of the work. It is important to emphasize that the use of “Microsoft Copilot” was exclusively instrumental, not replacing the researcher’s analytical interpretation. All categorizations and conclusions presented resulted from the author’s own critical evaluation.

3. Results and Discussion

The analysis of the collected data, from both specialized literature and legislation, as well as from interviews with Compliance professionals, revealed that the ethics channel has consolidated itself as a fundamental mechanism for detecting irregularities in the corporate environment. It was observed that, despite regulatory incentives and its proven effectiveness in identifying deviations, there is significant resistance to its use by stakeholders. This resistance stems mainly from a perception of distrust and an inadequate understanding of the channel’s purpose and limits, which compromises its credibility and, consequently, its effectiveness in promoting a culture of integrity.

Specialized doctrine, according to Espín (2017), highlights the importance of the “whistleblower” in revealing financial and corruption scandals, driving the adoption of systems for protecting reporters, such as the Sarbanes-Oxley Act (SOx) in the United States. Guillén Ortega (2021) defines the channel as an internal oversight strategy that allows stakeholders to report irregularities, enabling the investigation of facts and the application of corrective measures. Giovanini (2016) complements this, emphasizing the tool’s role in risk management and the design of internal controls, as well as its pedagogical function in raising awareness of irregular behaviors.

In the Brazilian context, legislation recognizes the relevance of the whistleblowing channel as an essential component of integrity programs. Decree No. 11,129/2022, which regulates the Anti-Corruption Law, and Decree No. 12,304/2024, which regulates the Law on Public Procurement and Administrative Contracts, establish the channel as one of the parameters for evaluating these programs. Additionally, Law No. 14,457/2022 made the implementation of this instrument mandatory for companies with an Internal Commission for the Prevention of Accidents and Harassment, aiming to combat sexual harassment and other forms of workplace violence, which reinforces the regulatory support for its existence and operation.

Empirical research, based on interviews with Compliance professionals, confirmed the perception that an effective ethics channel allows for the identification of irregularities that would often escape traditional internal controls. The interviewees highlighted that the channel enables the internal and swift handling of deviations, which reduces legal, financial, and operational impacts, mitigating costs associated with external exposure. This internal response capability, according to Silva and Sousa (2017), tends to generate less severe impacts than the public disclosure of sensitive information, preserving the organizational image and strategy.

Additionally, the interviewed professionals emphasized that the channel contributes to the improvement of risk management and to the generation of institutional learning from detected and addressed irregularities. This perspective aligns with Saad-Diniz’s (2019) positioning, which advocates for a systemic performance of the channel, capable of producing qualified metrics on the organizational capacity to identify and respond to harmful conduct, overcoming a merely punitive view. The mechanism, therefore, not only detects but also acts preventively, inhibiting inadequate behaviors and strengthening an organizational culture oriented by ethics, transparency, and responsibility.

Despite these benefits, the main fragility identified for the proper functioning of the ethics channel lies in the widespread difficulty of stakeholders in understanding its real purpose and limitations. This misunderstanding, according to most interviewees, stems from inconsistent institutional communication. It was observed that whistleblowers frequently interpret the channel as a police or judicial instance, expecting immediate and severe punishments. When investigations do not result in visible sanctions, the common perception is that “nothing was done,” compromising the credibility of the process.

To mitigate this communication barrier, the need for continuous acculturation of the involved audiences became evident. It is essential that institutional communication distinguishes the ethics channel from other internal channels, such as those for people management or customer service, and limits its use to issues of a corporate nature, moving away from its application to strictly personal problems. Discourses that anticipate value judgments, “zero tolerance” rhetoric, or promises of automatic punishments should be avoided, as such stances create expectations incompatible with the technical and impartial nature of the instrument.

The adoption of clear, accessible, and continuous training and communication actions, aligned with the institutional reality and directed at diverse audiences, is an essential practice. Wide dissemination of the channel through institutional channels such as corporate websites, intranets, newsletters, and social media ensures that any interested party can register complaints. The inclusion of detailed information about the channel’s operation and guarantees in the codes of conduct for employees and third parties, as pointed out by the interviewees, facilitates access to information and reinforces guidelines organically.

Coherent communication at the time of registering the complaint, through “disclaimers” on the tool’s “front-end”, also proved crucial. These notices should clarify the channel’s operation and limitations, the safeguards offered to the whistleblower, and the type of feedback that can be provided. This initial communication, when conducted with objectivity and transparency, allows for the establishment of realistic expectations and contributes significantly to building the trust necessary for the appropriate and responsible use of the mechanism, demystifying misconceptions about its purpose and scope.

The simplification of language in institutional communication was another relevant point highlighted. Excessively technical or abstract discourses tend to alienate organizational actors. It is recommended to translate concepts such as ethics, integrity, and risk management into concrete everyday situations, using analogies with family and social life. This strategy facilitates the understanding and internalization of content, strengthening the sense of belonging and demonstrating that integrity practices are not foreign to human experience, but integrate intuitive processes already experienced by individuals.

However, it is recognized that a residual portion of people may use the ethics channel in bad faith, with the intention of defaming or slandering. In such cases, it is essential to clarify that such situations do not warrant the enjoyment of safeguards intended for good-faith whistleblowers. Once the falsity of the information is proven, appropriate measures must be taken, including legal and disciplinary accountability, to preserve the integrity of the system and prevent the misuse of the tool.

The role of senior management, often termed “tone at the top”, is a determining factor for the channel’s credibility and the consolidation of an integrity culture, according to Veríssimo (2017). The effective support of leadership, combined with the public expression of this commitment, directly influences the values and norms that guide the institution’s actions. However, the interviewees stated that leadership itself, in some situations, adopts stances that compromise the robustness of the mechanism, such as fear of personal exposure, the perception of a threat to their power, or viewing the channel as a merely formal cost.

The possibility of interference in investigations involving members of senior management is a circumstance that weakens the integrity management system. In this sense, leadership acculturation is essential and demands specific treatment, with the creation of spaces for dialogue so that they can express fears and doubts openly. It is necessary to demystify the ethics channel, presenting admissibility criteria, filters, and screening stages, so that it is perceived as a risk management tool, rather than for punishment or surveillance, promoting a more strategic understanding of its value.

The presentation of empirical evidence to leadership, such as the discussion of concrete cases and practices adopted by organizations with a higher degree of Compliance maturity, aids in the formative process. This approach demonstrates the channel’s performance in risk reduction and process improvement, highlighting its relevance in detecting and addressing irregularities. Once engaged, senior management becomes able to demonstrate its effective support to other stakeholders, actively participating in institutional communications and issuing spontaneous messages, beyond scripted speeches, strengthening the process’s legitimacy.

The process for receiving and handling complaints must be clear and well-defined. Nieto Martín (2018) argues that effectiveness and adherence to regulations depend on the ability to detect infractions, investigate them adequately, and apply sanctions. Within the scope of corporate integrity, this implies the adoption of policies and procedures that clearly delineate the stages of receiving, screening, investigating, and remediating deviations. The creation of a structured stage for preliminary screening and plausibility assessment, carried out by a specific area or technical professional, is fundamental to identifying minimal evidence of authorship and materiality, filtering out emotional elements, and producing an objective version of the complaint.

Once the screening is overcome, the Compliance area must verify, based on objective criteria, whether there are sufficient elements to initiate a formal investigation, following a standardized procedure applicable to all involved, including members of senior management, to avoid casuistry. The investigative stage requires refined technique and functional independence, with strict confidentiality protocols and the prohibition of access by uninvolved persons. The interviewees agreed that the channel only generates credibility when operated with good technique, stable rules, and the absence of undue interference.

The integration between the areas and instances involved in the investigative process is crucial for the coherence, legal certainty, and technical consistency of the workflow. This includes the team responsible for receiving and screening, the Compliance area for investigation, the legal area for legal analysis, the ethics committee for strategic deliberation, and the manager responsible for the execution of disciplinary measures. The elaboration and dissemination of specific, accessible, and detailed internal regulations, governing everything from registration to the final feedback, with clear deadlines and safeguards, are essential measures to strengthen the credibility of the mechanism.

Whistleblower protection, with the preservation of anonymity and the prohibition of retaliation, is a prerequisite for the legitimacy and functionality of the ethics channel. García Moreno (2018) recommends providing multiple access routes, such as electronic forms, telephone lines, emails, and in-person service, allowing the whistleblower to choose the most comfortable means. Spinelli (2018) complements this by suggesting registration methods that allow the whistleblower to define the degree of exposure of their identity: fully anonymous, confidential, or identified, with clear guarantees for each option.

Giovanini (2016) points out structural fragilities in the internal management of anonymity, such as voice recognition or IP tracking, and suggests the channel’s administration by an external and technically qualified business society to reduce risks of exposure and conflicts of interest. The prohibition of retaliation is particularly sensitive in labor relations, where power asymmetry can dissuade the reporter, as highlighted by Espín (2017). Concrete measures, such as the temporary transfer of the whistleblower or the removal of the accused, can prevent retaliation, according to Guillén Ortega (2021), and suppliers and third parties should also be protected, according to Spinelli (2018).

The operationalization of the non-retaliation policy is complex and requires a case-by-case assessment of proportional and reasonable measures, to protect the good-faith whistleblower without shielding them from performance evaluations or legitimate job changes. The robustness of this prohibition depends less on absolute guarantees and more on the ability to maintain the integrity of the investigative process and the regular management of labor relations. This balanced approach is fundamental to ensure that protection is not misused and the channel maintains its purpose of promoting integrity.

The feedback to the whistleblower and the disclosure of results are sensitive aspects, given the tension between the confidentiality of the investigative process and the preservation of the tool’s credibility. Although there is no legal obligation in Brazil for private organizations to disclose deviations, the absence of feedback can generate a perception of institutional inertia. Empirical research showed that, although the whistleblower acts as a collaborator of the integrity system, the decision to report often involves a significant emotional component, and the feedback demonstrates that the case was treated with seriousness and diligence.

In cases of harassment and discrimination, where the complainant and the victim often overlap, the absence of any feedback can be perceived as institutional denial of the suffering experienced. It is recommended that feedback be provided cautiously, without exposing details of the investigation and remediation measures, and that it can be delivered verbally, reducing the perception of inaction and preserving confidentiality. In addition to individual feedback, periodic and anonymized disclosure of aggregated results, with the suppression of names, positions, and identifying elements, strengthens transparency and serves as a pedagogical tool, demonstrating that complaints produce concrete effects.

The disclosure of the accused’s hierarchical level, even if broad and devoid of details, demonstrates fairness in the application of disciplinary measures, one of the main challenges to the channel’s credibility. The results may include the improvement of internal processes, the review of controls, and learning from failures, publicizing these effects as a demonstration of contribution to the culture of integrity, even when they do not culminate in individual punishments. The compilation and systematization of data for publication allow for an aggregated analysis, identifying recurring patterns and directing training and communication actions.

Monitoring the ethics channel, through perception surveys, is a common practice that should distinguish the evaluation of the channel as a reporting mechanism from the evaluation of the investigation process. Generic questions that mix these two processes can generate distorted diagnoses. It is recommended that the initial evaluation focus on objective criteria of quality and usability of the tool, such as ease of access, clarity of guidelines, and guarantees offered. Only after this stage would it be appropriate to examine employees’ perception of the conduct of inquiries and the impartiality of the process.

This methodological distinction allows for the precise identification of potential channel failures, enabling the adoption of corrective measures aimed at its improvement. Conducting routine quality tests, from the end-user perspective, evaluating aspects such as response time, service availability, and technical stability, is equally important, especially in multinational organizations. The periodicity of perception surveys and the formation of focus groups to analyze and deepen the captured data are essential to avoid superficial or distorted interpretations of the results.

Regarding moral harassment, sexual harassment, prejudice, and discrimination, an expressive increase in cases reported through ethics channels was observed, surpassing reports of fraud or corruption. In these cases, the whistleblower is frequently the victim themselves, which gives the report a high emotional burden and a strong expectation of institutional recognition. It is crucial to develop a specific analysis of the topic and measures for the adequate reception, investigation, and treatment of these situations, distinguishing them from generic complaints or interpersonal conflicts that should be handled by people management.

An essential practice is acculturation regarding what effectively characterizes harassment and other forms of workplace violence, with the development and wide dissemination of educational booklets and specific training. It is also necessary to provide clear information about the instances responsible for handling complaints that do not fall within the scope of the ethics channel, adequately guiding interested parties. The clear delimitation of investigative action, especially in cases where the evidentiary record is limited to the word of the complainant and the accused, is fundamental to avoid automatic and excessively punitive responses.

The investigation must be thorough, valuing the victim’s account, but without assuming it as absolute truth, to avoid injustices. Transparency in the relationship with the victim, especially when the investigation does not result in disciplinary action due to insufficient evidence, is crucial. The culture of integrity demands a balance between sensitive support for the victim and respect for the investigated party’s guarantees, preserving impartiality and the investigation’s technical rigor. Institutional signaling that every harassment complaint will be automatically considered valid can even foster “false accusations”, encouraging the misuse of the mechanism.

Finally, the handling of complaints involving historically vulnerable groups, such as women, Black people, people with disabilities, and the LGBTQIAPN+ community, deserves special attention. The channel’s construction should adopt an inclusive approach, recognizing and responding to the different needs of these stakeholders. Creating spaces for guidance and dialogue aimed at social minorities, even before the formal registration of a complaint, can empower individuals and strengthen the trust necessary to use the tool. The inclusion of clear and accessible information in institutional diversity and inclusion campaigns reinforces the existence of the ethics channel and the commitment to preventing discriminatory conduct and workplace violence, contributing to reducing symbolic distance and strengthening the perception of the mechanism’s legitimacy.

In summary, the research demonstrated that the ethics channel is a strategic pillar for organizational integrity, capable of generating institutional learning and strengthening ethical culture, but its effectiveness is intrinsically linked to stakeholder trust. The identified weaknesses are predominantly communicational and cultural, not technological, and can be mitigated by consistent communication strategies, continuous training, senior management engagement, and a structured treatment flow. These good practices, such as individual feedback and anonymized disclosure of results, are accessible and high-impact, contributing to a culture of integrity that values transparency and the technical handling of irregularities, responding directly to the objective of strengthening trust in the channel.

4. Conclusion

The present study aimed to examine the main difficulties related to the implementation and operation of the ethics channel, as well as to identify measures capable of mitigating these barriers and strengthening its credibility before internal and external audiences. It was found that, despite its relevance and regulatory support, the ethics channel faces resistance to use, stemming mainly from distrust and inadequate understanding of its purpose and limits by stakeholders. The findings indicated that the most recurrent weaknesses are of a communicational and cultural nature, not technological. It was identified that clear institutional communication, continuous training, engagement from senior management, a structured processing flow, safeguards for the whistleblower, careful disclosure of results, and permanent monitoring are essential requirements and good practices. These measures contribute to strengthening trust in the mechanism, promoting a culture of integrity that values transparency and the technical handling of irregularities.

However, it is recognized that the research has limitations, such as the sample being restricted to professionals from private organizations, which prevents the generalization of results to other sectors, such as public administration. Additionally, the focus on federal legislation did not cover state, regulatory, or international norms that could influence the operation of the ethics channel in different contexts. The qualitative nature of the analysis, although suitable for the exploratory objective, does not allow for statistical inferences or universalizable conclusions, but rather contextualized interpretations of the perceptions collected. For future studies, it is suggested to conduct quantitative investigations on the perception of collaborators in various economic sectors, longitudinal research to evaluate the evolution of institutional maturity after the implementation of good communication practices, and specific analyses on cases of retaliation, the impact of organizational culture on whistleblower behavior, and the effectiveness of hybrid channel management models. The increasing litigation of issues such as harassment and discrimination also points to the need for interdisciplinary studies that integrate compliance, labor law, and organizational psychology.

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