The Enemy Within: Can whistleblowers rely on you?

Not so long ago, I was remotely managing an investigation into corruption allegations in a country pretty far down TI’s Corruption Perceptions Index.* The allegations had come from a whistleblower, and were serious and complex.

pexels-photo-587063The lead investigator had just returned, fresh off the plane and into our update meeting with the rest of the team. We sat down in a comfortable meeting room, thousands of miles away from the dusty, hectic and often frightening city in which the allegations had arisen. The city was one of those places that was sort-of a conflict zone, sort-of a disaster zone, sort-of a global city and sort-of none of these things. Development specialists and humanitarians worked shoulder-to-shoulder, and projects evolved quickly in response to an endlessly changing local environment.

“Yeah, so, I interviewed the snitch,” she began, with a cheeky smirk.

I stopped the meeting.

“The what?” I said.

Portrait of two beautiful young girlfriends sitting in modern co

‘Snitch’, ‘grass’, ‘squealer’ – this was not the first time that I’d heard investigators themselves using pejorative euphemisms for whistleblowers, informants and sources. It is bizarre; often, without such sources, there would be no investigation. So where does this attitude come from?

There is another dimension of anti-corruption work that’s similarly full of euphemisms, and might offer an answer –  and that’s the act of bribery itself. As Richard Bistrong memorably said, “the language of bribery has many words – except ‘bribery’.”

A ‘drink’, ‘gravy’, ‘tea-money’, ‘consultation fees’ – such language is often an exercise in re-framing, a way to alleviate discomfort with bribery by using words that carry different (and lighter) connotations. So, is the truth that some investigators are uncomfortable with whistleblowers – that there is a deep aversion, perhaps culturally-rooted, to people who ‘tell on others’?

Fortunately, I don’t think many investigators fit into this category, but there are enough that we need to talk about the tension here. Firstly, the truth is that whistleblowers and their reports are the lifeblood not just of an investigation, but of an entire fraud and corruption control framework. Without these reports, we would not necessarily be able to:

  • Gain prior warning of materialising fraud and corruption risks;
  • Conduct trend analysis of risk areas (especially where reports did not contain sufficient data for full action);
  • Plug whistleblower data back into our risk assessment, honing our deterrence and prevention controls;
  • Evaluate the quality of our anti-fraud and corruption culture.

pexels-photo-568027Secondly, whistleblowers face enough challenges already. From stakeholders obsessed with identifying them, to those who try to use the whistleblower’s motivations as a shortcut for judging their credibility (and no – just because a whistleblower is motivated by reward or revenge, it does not mean that their allegations are untrue). Investigators play a critical role in mitigating these risks to them.

Thirdly, and this might come as a surprise to some investigators – whistleblowers don’t just talk to you. So if you fail in your management of them, chances are people will find out – and that impacts upon the chances of anybody else sharing information with you in future. There are more whistleblower horror stories than success stories. After all, if we handle a whistleblower really well, who ever really finds out that there was one?

What kind of investigator are you?

pexels-photo-356079Every so often, I hear investigators at conferences speculating (or riffing online) about what sort of people become whistleblowers. I wonder if a more pertinent question is, what sort of investigator are you? And in particular, how much attention do you give to your eternal, internal battle against cognitive biases, heuristics and errors – a battle critical to maintaining your objective investigative mindset?

Whistleblowers are real people, who for whatever reason, have placed themselves at some risk. I have seen these risks materialise, and it is not pretty. So, how can we ensure that our investigative practice sees whistleblowers as constructively as possible?

16404-a-woman-in-a-business-meeting-pvReflect on your own attitudes. What assumptions do you make, and bring to work? Are they valid, or are they biases? How might they affect your work? What could the consequences be?

Treat whistleblowers as an asset. Although an investigator is not necessarily there to be an ‘advocate’ for a whistleblower, they should ensure that the whistleblower’s material is treated objectively and securely, that they are treated fairly, and that the risks to them are properly identified, considered and managed as far as possible.

Business agreement deal at coffee shopEmbrace hot and cold debriefs. (Or ‘immediate and delayed’ debriefs.) Adopt a cycle of evaluating your own performance and incorporate how you handle whistleblowers into it. Handling a whistleblower includes how you interact with them, treat their information, manage the investigation around them, and manage other stakeholders.

Challenge the litany of euphemisms. Language affects how we think and act. Let’s call whistleblowers by their proper designations – confidential sources, confidential informants, confidential reporters, whatever the term your organisation or local regulatory environment uses. Don’t let investigators call them ‘snitches’.

The way that we allow ourselves to think about those who participate in our investigations can be the enemy within us. We need to manage it as we would manage any other risk.

FFCHGDS* Details have been changed. Images do not necessarily represent the locale or persons described.

Find out more about handling whistleblowers, building a meaningful fraud and corruption control framework, and more for humanitarian and development organisations in Fighting Fraud and Corruption in the Humanitarian and Global Development Sector (Routledge, 2016).

It’s out now – treat your office!

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Silent Partners: Are you working with a local NGO that doesn’t exist?

In this guest post, experienced global development finance professional Najwa Whistler describes her experience investigating ghost NGOs in a conflict zone. Names and details have been changed.

roadSome years ago, I found myself investigating events in a program in a war-torn country. The program had been set up to build the capacity of small local NGOs to implement community development projects. The concept was great, the donor funding had been secured, local partner NGOs had submitted proposals and agreements had been signed, transfers had been made and reports had been received. The only problem was that most of these NGOs didn’t exist.

In development sector investigations, one of the first actions upon arriving in-country is to meet with the local program director and understand how the concerns began. But within moments of sitting down with Nancy, I could already start to see how the fraud had arisen.

afghanistan-60668_1920Ex-pat Nancy used to be a teacher in Canada, and this was her first job in an international NGO. She was young, and idealistic, but it was clear that she did not have the relevant skills and experience. A conflict zone is a dangerous and stressful place, often with high staff-turnover, and the international NGO had compromised on her qualifications to find someone willing to endure the hardship.

As I talked through Nancy’s concerns that their local partners might not exist, two things became very clear. The first was that Nancy did not have field trip and progress reports and had not visited their offices.

“Why?” I asked.

“Oh, I can’t visit, it’s too dangerous,” she said.

The second was that, instead, Nancy had relied heavily on a single individual to manage this project.

“Can I see the checklist for the review of the partners’ proposals, and who was involved in the decision making?” I asked.

Nancy nodded. “Raj, the national program manager, reviewed the proposals and approved them – then he prepared the contracts.”

Raj had worked for the international NGO for many years.  In his late forties and a man of few words, he was a hard worker – the first in the office, the last to leave, and rarely took a day off. Nancy delegated most of her tasks to him.

volkswagen-569315_1920When my team drove out to the field to visit the partners and the communities, I went with Malik, a driver, who turned out to be Raj’s brother. The driver tipped off the ‘NGOs’ that we were coming for a visit.

Malik took us to a building consisting of five rooms and a hall way. On the door of each room was a crisp, freshly printed A4 paper with the name of each ’NGO’. In each room sat one man, the ‘managing director’ of each ‘NGO’. Solidarity, cooperation and co-ordination between NGOs at its best perhaps, and rarely seen to such an extent!

Malik was not the only person I met that day close to Raj. All five men came from the same village, and the same kinship group, as the brothers. This was surprising too – as the community development projects were in an area where the majority of locals were from a different kinship group – one with a long history of conflict with that of the brothers.

Over the day, I sat with each ‘managing director’ and asked about the progress of the work, the challenges, their records and their reports. Not one could locate any team members, volunteers or records with whom I could engage.

“I keep the documentation at my house because it is not safe to keep them in this building,” said one. Perhaps unsurprisingly, he would not allow us to follow him to his house or wait while he retrieved the documents as the house was ‘too far’.

Unfortunately, this picture is not unusual. But the red flags were visible in this case – and there are things we can do to better spot them and manage these risks.

office-594132_1920Firstly, ensure a realistic and validated assessment of potential partners takes place. More than one person or function needs to be involved in this assessment, and it should compare project proposals. Involve logistics and procurement teams to verify market rates.

Secondly, constantly review your project management approach during its lifecycle. Perform regular visits to the projects when the security situation allows. Ask the team members of the local partner organisation to meet you at your office from time to time.

Thirdly, even in environments where we trust our colleagues, ensure that you take a robust approach to verification. If security doesn’t allow you to physically visit the project, perhaps you can ask for GPS located photos of activities – and do not be afraid to ask for them again if the first ones look odd! Interview beneficiaries over the phone. Talk to donors and other international organisations working in the same area about their experiences.

passport photoNajwa Whistler is a finance director with 18 years of experience working for several international NGOs around the world. Growing up in a small village in Lebanon in poverty during the civil war built her resilience and determination to work in international development. She enjoys cooking and dancing. You can reach her via naj.whistler@gmail.com