The Triage Process: The 3 Rs

Having a triage process as part of your investigation methodology is extremely helpful when assessing how issues will be handled, especially in the context of internal complaints, concerns, allegations and reports. It is all about having a stable system in place.

Think of your triage process as a three-legged stool; if one leg collapses, the entire structure crumbles. Each stage is just as important as the other!

Working out which triage process to use, however, is an important consideration.

Although it is different for every organisation, at Parametric Global Consulting, we recommend the ‘three Rs’: the React; Respond; Remediate’ triage system.

What should organisations do at each step?

Step 1 – React!

An organisation’s reaction to concerns is all-important. It sets the tone for how adequately a report will be handled and can make or break trust in an organisation’s culture and approach to handling misconduct.

The organisation should be swift but considered in acknowledging the complaint, as failure to do so may mean employees are forced to escalate their concerns outside the organisation. The chances of external reporting are increased if the complainants are of the view that business leaders will not even acknowledge the existence of their concerns, regardless of validity.

In addition to damaging workplace trust and confidence, this can lead to huge reputational risks and external scrutiny.

Reacting does not always mean starting a full investigation; it will depend on the severity of the report. Nevertheless, it means always providing reassurance to those who speak up, to ensure they feel heard. This will encourage employees to come forward boldly, reduce fear of retaliation, enhance business integrity, and avoid long-term concealment of issues.

Step 2 – Respond!

Responding adequately once an allegation or concern is raised, is as crucial as reacting appropriately. Working out the best way to respond isn’t always straightforward. Considerations may include the timing and nature of a response, and understanding what an effective response looks like.

Your organisation may have systems or procedures in place to manage responses to issues that have arisen via hotlines, internal reporting, or other means. Remember that your response may be scrutinised by law enforcement or regulators at some point. They may examine failures to respond to an identified issue, or failures to respond in a meaningful way.

Ensuring that a response is effective, is vitally important; the response should be tailored to the nature of the issue. An effective response is one that distils all relevant factors in a constructive and timely manner and sets out a clear plan of action. The plan should be executed using skilled and trained personnel.

A ‘sweep under the carpet’ mindset will damage trust and affect organisational culture. Tailored, active responses lead to effective resolutions and ensure that those who come forward, feel properly engaged with.

Step 3 – Remediate!

A concern has been raised. Your organisation has effectively reacted and responded, and there is a clear problem to resolve. What next?

Remediation is the third pillar of the triage structure, and it is key. It is one of the main reasons for reporting concerns because ultimately, people want something done about it. A failure to remediate effectively after a legitimate issue(s) has been uncovered, will undo the work undertaken during the first two steps of the triage process.

However, this does not mean treating remediation as a mere ‘tick-box’ exercise. Poor remediation can damage trust and the organisational culture. It can create feelings of disengagement, reduce business integrity, and diminish confidence in the organisation’s approach to handling misconduct.

Remediation determines whether an organisation can ‘walk the talk.’ Inadequate remediation can heavily suppress a culture of speaking up. A lack of follow-through can be demoralising and may increase the likelihood of issues being concealed and made worse or reported externally.

It may not always be clear to the organisation at large that remediation has occurred due to the sensitivity or nature of an investigation. If it is inappropriate to disclose the outcome, care must be taken to manage the expectations of those involved as witnesses.

Any crisis can be made infinitely worse by a head-in-the-sand mentality. It is important for organisations to execute a remediation plan of action and do what is necessary. They should take the steps needed to ensure that organizational values and principles remain intact.

Takeaways:

• Do you have a clear and effective triage process? Do you have a clear framework for your investigation process?

• The initial reaction to a complaint or allegation can either instil confidence or dismantle trust in the process.

• The failure to react in a considered and timely way can quickly escalate the situation.

• Failure to respond meaningfully can draw scrutiny and/or criticism from law enforcement and regulatory bodies.

• Are relevant employees properly trained with the skills to triage and conduct any necessary investigations?

• Manage expectations about disclosure of outcomes and remediation.

Organisations that spend time and resources in crafting a triage process will be well-equipped in times of crisis. With global indicators pointing towards a notable increase in financial crime risks, now, more than ever, organisations must encourage a ‘speak up’ culture.