Beware of Toothless Tigers: Institutionalizing Whistleblowing May Crowd Out Compliance

Sebastian Kruegel, Matthias W. Uhl
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Abstract

Internal whistle-blowing systems are supposed to fight misconduct within organizations. Because it is difficult to study their efficacy in the field, scientific evidence on their performance is rare. This is problematic, because these systems bind substantial resources and might generate the erroneous impression of compliance in a company in which misconduct is prevalent. We therefore suggest a versatilely extendable experimental workhorse that allows the systematic study of internal whistle-blowing systems in the lab. As a first step, we tested the efficacy of whistle-blowing systems if internal punishment for misconduct is mild and hesitant which is usually the case in practice, as several fraud surveys confirm. Our results show that under these conditions almost nobody blew the whistle, and misconduct occurred even more frequently with than without a whistle-blowing system. The institutionalization of whistle-blowing seemed to crowd out the intrinsic motivation to act compliantly. Moreover, when a whistle-blowing system was either unavailable or not used, misconduct was highly contagious and spread quickly. Yet, when we implemented severe and ensured punishment for misconduct, whistle-blowing systems could deter wrongdoing. In such a setting, people were willing to blow the whistle and the prevalence of misconduct dropped substantially. Altogether, our results highlight the interaction between institutions and preferences and can support the design of compliance measures within organizations. For compliance managers a key takeaway is that if companies preach a zero-tolerance policy, they should practice it as well. Otherwise, they might even worsen the situation.
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小心没有牙齿的老虎:制度化的举报可能会排挤合规
内部举报系统本应打击组织内部的不当行为。由于很难在实地研究它们的功效,因此关于它们性能的科学证据很少。这是有问题的,因为这些系统绑定了大量资源,并可能在行为不端盛行的公司中产生合规的错误印象。因此,我们建议一个多用途可扩展的实验工作马,允许在实验室内部检举系统的系统研究。作为第一步,我们测试了举报系统的有效性,如果对不当行为的内部惩罚是温和和犹豫的,这通常是实践中的情况,正如几项欺诈调查所证实的那样。我们的研究结果表明,在这种情况下,几乎没有人举报,而且有举报制度的不当行为发生的频率甚至比没有举报制度的情况还要高。举报的制度化似乎排挤了采取顺从行动的内在动机。此外,当举报系统无法使用或没有使用时,不当行为具有高度传染性并迅速蔓延。然而,当我们对不当行为实施严厉和有保障的惩罚时,举报制度可以阻止不法行为。在这种情况下,人们愿意举报,不当行为的发生率大幅下降。总之,我们的结果突出了制度和偏好之间的相互作用,并且可以支持组织内的遵从性措施的设计。对于合规经理来说,一个关键的收获是,如果公司宣扬零容忍政策,他们也应该这样做。否则,他们甚至可能使情况恶化。
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