Whistleblower Hotline, Policies & Internal Controls
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At Glotfelty PLLC, we help nonprofits and small businesses build and maintain effective, legally compliant whistleblower and internal reporting programs that foster trust, accountability, and transparency. Our attorneys have extensive expertise in building effective whistleblower programs, creating policies, operating hotlines, and conducting internal investigations. We have drafted and implemented whistleblower policies, as well as led internal, civil, and criminal investigations of whistleblower complaints, at multiple federal agencies’ Offices of the Inspector General. Our attorneys have presented at national conferences in front of Congressional staff, government agencies, whistleblower-related nonprofits, and businesses.
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We understand that nonprofits and small businesses often desire to implement whistleblower programs and hotlines but find the costs to be prohibitive – that’s where we come in. We have developed a unique, affordable service that serves as the whistleblower hotline equivalent of micro-lending.
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The Challenge: Based on our market research, experience vetting major providers, and discussing with nonprofits and small businesses, we found that standard hotlines easily start in excess of $10,000 annually and can run into six figures for large companies or complex needs. In addition to the direct cost, a company must work with a team of developers to customize their hotline, train staff to operate it, and then dedicate staff time to the operation indefinitely.
Our Solution: By pooling resources across multiple participating businesses, Glotfelty PLLC is able to effectively customize, operate, and maintain a shared hotline service that meets the needs of smaller organizations at a fraction of the normal price.
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Value of a Strong Whistleblower Program and Hotline
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When aligned with strong whistleblower policies and procedures, a hotline facilitates open communication between staff and leadership and demonstrates an organization’s commitment to good governance, transparency, and ethical conduct. Having a hotline is widely recognized as a best practice. Key benefits include:
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Safe Reporting Channels: Providing safe and secure lines of communication, with the option of anonymity, empowers staff to speak up and elevate concerns – such as potential fraud, waste, abuse, serious mismanagement, or other misconduct – to senior management or the Board without fear of retaliation or stigma.
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Early Risk Detection & Internal Mitigation: When staff feel unheard, they may turn outside the organization, such as to the media, stakeholders, courts, or government regulators. A hotline encourages internal reporting, giving the Board and leadership early notice of potential problems and an opportunity to mitigate before these issues escalate into negative media attention, loss of donor trust, costly lawsuits, or government scrutiny.
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Transparency & Accountability: Strong internal reporting systems strengthen compliance programs and signal credibility to donors, the public, and government oversight authorities. Demonstrating your organization proactively identifies and addresses risks can help build trust and confidence that your organization is a responsible steward of charitable funds.
Are Whistleblower Hotlines or Internal Control Systems Required?
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The concept of whistleblowing has evolved into a critical component of sound governance for both public and private entities. In fact, many organizations are required under federal or state law to maintain internal control systems, such as a hotline. Such requirements may arise under federal contracts, federal programs, grants, or state laws. For example:
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Federal contractors: Federal contractors who meet certain thresholds have an affirmative obligation under FAR 52.2023-13 Contractor Code of Business Ethics and Conduct to exercise reasonable due diligence to prevent and detect criminal conduct, including a compliance program and sufficient internal controls to timely detect and mitigate risks. The FAR lists the minimum internal control requirements, including assignment of adequate resources and responsibility under a sufficiently high-level official, periodic reviews including monitoring, auditing, and risk assessments, an internal reporting system like a hotline, and remedial action, as needed, including discipline or disclosure to the government.
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Specific Federal Contract or Program Requirements: Individual federal contracts or specialized federal contracting programs may impose similar requirements to the FAR. For example, nonprofits participating in the AbilityOne Program are required under Commission Policy 51.406(5)(c)(ii) to establish and maintain “an effective system for receiving and investigating complaints from participating employees.”
Our Whistleblower Hotline
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Our hotline is hosted by Navex, a risk and compliance solutions company that provides hotline services for thousands of companies including major corporations like Dell Computers. Our hotline offers:
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a 24/7 phone service available in the U.S., Gaum, and Puerto Rico;
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a custom webform to submit complaints;
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the ability to create an anonymous username to encourage contact by individuals who may fear retaliation or may simply wish to remain unidentified; and
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sophisticated back-end software management.
In addition to the technical capabilities, Glotfelty PLLC’s clients gain access to former federal investigators and attorneys with deep expertise in identifying potential legal, compliance, or ethical issues. We provide both legal counsel or internal investigative services, as necessary. Our services are governed under applicable attorney client privilege, confidentiality, and work-product rules, adding extra security and privacy to our clients.
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Whistleblower Policy and Procedures Development
Hotlines are most effective when supported by clear, well drafted, and practical policies and procedures that guide how concerns are reported, reviewed, and resolved. Our firm assists organizations in developing comprehensive whistleblower policies that are:
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consistent with best practices and industry standards;
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compliant with federal and state law, including any grant or contracting program-specific requirements; and
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customized to meet the unique structure or mission of your nonprofit or business.
By embodying these policies into your broader compliance framework, we help create a culture of openness, accountability, and ethical leadership.
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Internal Investigations
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When a hotline complaint raises potential legal, regulatory, or ethical concerns or reveals weaknesses in existing compliance frameworks, a prompt and confidential investigation is essential. Glotfelty PLLC significant experience conducting internal investigations governed under attorney-client privileges, ensuring both discretion and legal protections for your organization.
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​To learn more about how a whistleblower program and hotline can strengthen your compliance, governance, and organization’s culture, contact Glotfelty PLLC to schedule a consultation.
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