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Oxfam – to disclose or not to disclose? That is the question

The Oxfam travails illustrate the age-old conundrum of what an organisation should do about rumours of impropriety. The temptation is to apply a very narrow and self-serving assessment of whether the rumours contravene the absolute letter of the law, as this allows the organisation to convince itself that as there is no “prime facie” case, hence there is no need to disclose anything to anyone.

In tackling this issue over many years, I know that local HR managers, normally the recipient of the rumours, are placed under huge internal pressure to not go digging, the fear from above being that if they go digging they will uncover the proverbial “can of worms”.

But this is akin to tip-toeing around and ignoring an un-exploded bomb.

In fact, the real issue is not the possibility of the potential explosion, but organisations don’t have a process for working out how big the bomb is and how to diffuse it.

So, what should you do about the rumours that constantly circulate and swirl around parts of your operation, often overseas?

The first thing is to realise that these rumours are telling you something about your organisation, but you don’t understand what is being said. What is needed is a process of refining and interpreting these coded messages. This is achieved by implementing an “intelligence” focused analysis / investigation, which can be rudimentary or sophisticated, depending on the nature of your charity and its operation.

Built into this should be a clear disclosure framework and tip-pointing criteria. You don’t have to disclose everything you find out, but you need to be reminded when you are in danger of starting to cover things up.

The timing of when and how to transition from an intelligence-led approach to a prosecution-led approach is never clear-cut, but having an independent perspective can help clarify when the time is right to engage with your regulatory authorities.

It is worth remembering that regulatory authorities don’t want any sudden explosions as it makes them look bad. If your organisation has a framework for harvesting the intelligence that rumours offer and a bias towards disclosure, when you find an unexploded bomb, I have found that the regulatory authorities will engage constructively and discreetly to resolve the issues you face – a lesson that Oxfam may now have learnt.


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