Mary Inman has spent her career representing whistleblowers under the SEC, CFTC, IRS, and other federal reward programs. Partner at Constantine Cannon, she sees the inside of the cases most companies hope they will never see. Her conversation on Reimagining Company Culture is a useful corrective: most companies overestimate how trustworthy their internal channels are, and that overconfidence is what produces the case files that land on her desk.
The argument is direct. A culture of trust is not a vibe; it is an infrastructure. People raise concerns when they believe the system will work. They escalate to outside counsel when they believe it will not. The number of internal reports vs. external complaints is one of the truest signals a company can read about its own culture.
The Real Role of the Chief Compliance Officer
Mary sees compliance functions split into two camps. The first treats the CCO as an enforcement arm: write the policy, train the workforce, document the audit trail. The second treats the CCO as a culture function: create the conditions where issues get raised early and resolved before they become enforceable. The first protects the company on paper. The second protects the company in practice.
EEOC data on workplace sexual harassment found that roughly 90% of people who experience workplace harassment never file a formal complaint. The pattern repeats for compliance. Most concerns die quietly long before they reach the CCO. The CCO whose job is to count complaints will see fewer of them. The one whose job is to surface them will see more.
The Myth of Employee Feedback
Companies often confuse the volume of feedback with the quality of it. Mary's experience says the opposite: many companies receive lots of feedback and almost none of it is the feedback that matters. The feedback that matters is the kind people sit on for months because they are afraid of the consequences. The systems that catch it look different from the systems that catch satisfaction surveys.
That is why anonymous reporting matters disproportionately. The volume is lower. The signal is much higher. A whistleblower hotline is a specific tool for the kind of report that an open-door policy will never catch.
What Does "Trust" Actually Mean in a Compliance Context?
It means a person who raises a concern believes three things. The system will hear them. The investigator will be objective. The outcome will not retaliate against them. Each of the three has to hold or the trust collapses.
How Do You Tell If Trust Is Eroding?
External complaints rising, internal reports falling. Anonymous channel volume dropping while exit interview themes intensify. ER cases stacking around a particular leader or business unit. Each is a signal worth investigating.
Advice for Starting a Speak-Up Culture
Mary's advice for companies trying to start a speak-up culture is unromantic. You cannot announce a speak-up culture. You have to build the infrastructure, prove it works through a few visible cases, and then publicize the result. The order matters. Companies that announce first and build later end up training their workforce that the announcement was theater.
The Three Pieces of the Infrastructure
First, multiple intake paths so a person can choose how to surface a concern. Second, a routing layer that gets the report to a qualified investigator within hours, not weeks. Third, a closeout that tells the reporter what happened, even when the answer is bounded by confidentiality.
What Actually Works for Building a Culture of Trust
Track Retaliation Claims as the Leading Indicator
Retaliation is the most common claim filed with the EEOC, accounting for more than half of all charges in recent years. Companies that track retaliation patterns internally usually catch the broken-trust signal before it escalates to a formal claim.
Make Investigations Boringly Predictable
The reporter wants to know what happens after they hit submit. Document the steps, the timeline, the protections, and the closeout. Predictable processes build trust faster than charismatic leadership.
Treat Outside Counsel as a Lagging Indicator
If the same business unit shows up in outside counsel cases more than once, the internal infrastructure has failed in a specific way. Investigate the gap, not just the individual case.
Where Employee Relations Fits
ER is the operating layer that makes the speak-up infrastructure real. A case management platform built for ER tracks every report from intake through closeout. The team gets the data to see patterns. The reporter gets the assurance the report is moving.
How AI Helps Investigations Without Compromising Them
Vera, the AllVoices AI co-pilot, drafts the first response, summarizes long files, and surfaces patterns across cases. Every judgment call stays with the human investigator. The drudgery moves to the AI.
Frequently Asked Questions About Speak-Up Cultures
What is the difference between a hotline and a speak-up culture?
The hotline is a tool. The culture is the set of behaviors that determines whether people use it. A great hotline inside a fearful culture sees almost no traffic. A modest hotline inside a trusting culture sees plenty.
Can anonymous reports be investigated thoroughly?
Yes, with the right tools. Anonymized two-way communication lets investigators ask follow-ups without breaking confidentiality. A modern whistleblower hotline supports this directly.
What is the legal protection for whistleblowers in the US?
It depends on the type of report. SEC and CFTC cases have specific reward and protection programs. State-level retaliation protections vary widely. Mary's practice is built around translating those frameworks for individual reporters.
How does retaliation usually show up?
Through subtle changes in assignments, exclusion from meetings, or shifted performance reviews more often than through dramatic actions. The companies that look only for dramatic retaliation miss the common pattern.
Should compliance and HR be the same function?
They overlap, but the disciplines are different. Compliance focuses on legal and regulatory exposure. HR focuses on people outcomes. The best teams partner explicitly without merging the roles.
How to Build an Investigations Function That Holds Up
Mary's view from outside counsel is that the difference between companies that produce defensible investigations and companies that produce litigation is a small set of operational habits. Documented timelines. Clear rules on conflicts of interest. Investigators trained on interview technique. Closeout reports that capture facts and decisions in a format that holds up to legal scrutiny.
The investment is not large in absolute terms; it is large compared to what most companies actually do. Workplace investigations infrastructure tends to pay for itself in the first case that would otherwise have escalated to outside counsel.
The Bottom Line for HR Leaders
Mary's perspective from outside counsel is a useful one. The companies that produce the cases that land on a whistleblower attorney's desk usually believed they had a healthy speak-up culture right up until the case landed. The gap between perception and reality is the work.
The infrastructure matters more than the announcement. Multiple intake paths, fast investigations, predictable closeouts, and a culture where retaliation is treated as a fireable offense rather than a workplace style. Gallup research showing managers account for at least 70% of the variance in team engagement on engagement variance points to the same lesson at a different altitude: the manager and the system together produce the trust signal.
See how AllVoices supports compliance and HR teams who want to build a real speak-up infrastructure.
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