What is a “malicious” hotline report?
Your internal reporting hotline is a tool. It serves a specific purpose, and an important one at that: to help the compliance team uncover instances of corporate misconduct, the company can rectify those errors and continue pursuing its business objectives in a legal and ethical manner.
So how should compliance officers address the risk that employees might try to use the hotline for other, improper purposes?
This question came up in a recent NAVEX webinar I moderated about how to promote your speak up program. At the end of a long discussion of why the internal hotline is so useful, a listener asked: “How can we convey that the hotline is not meant to justify poor employee performance or to be used as a tool to harm others’ reputation through false reports?”
It’s a provocative question, but also an important one. The success of your internal hotline depends on trust. The moment employees stop trusting the hotline – say, because they get the notion that coworkers misuse the hotline to protect themselves or to harm others – your ethics and compliance program will be stuck under a cloud of suspicion.
Understanding the root of the problem
First let’s define the two “abuse cases” a compliance officer is most likely to encounter:
- One employee using the hotline to make a false report about another. For example, “John took the promotion I deserved, so I’ll accuse him of a conflict of interest,” or “Nobody gets along with Stacy; let’s accuse her of security breaches so we can get her on a performance plan and then fire her.”
- An employee who fears they’re going to be fired, so they file a frivolous hotline report believing that will give them protected status: “They’ll never lay me off now that I’ve made allegations of improper business practices.”
We don’t know how often malicious reports like the ones above actually occur. Clearly, they do, since every compliance officer seems to have a story about them – but concrete, quantifiable data on the subject is hard to find.
For example, NAVEX’s annual Whistleblowing & Incident Management Benchmark Report does track substantiation rates for calls to the internal hotline. That rate was 44% across all hotline calls in 2025, suggesting an unsubstantiation rate of 56%.
Unsubstantiated reports are defined as “reports that, when investigated, prove to be inaccurate as reported.” That means abusive reports are a subset of unsubstantiated reports, but motive is what matters here. There’s a world of difference between an employee who makes an erroneous report with good intentions and one who deliberately makes a false report. How many unsubstantiated reports are also deliberately false? Nobody knows for sure.
All that said, compliance officers should step back and appreciate what malicious hotline calls are really about: people using the hotline to pursue their own objectives – which might be quite improper – rather than the compliance team’s objective of rooting out misconduct.
That’s the misalignment you want to avoid. Your employees need to understand, and embrace, that the hotline should only be used for its intended purpose.
Delivering the right message
If the goal is to convince employees not to use the hotline for malicious calls, compliance officers need to take several steps.
For starters, have a policy that explicitly states the hotline should be used only for legitimate concerns. Stress that abuse of the hotline will be taken seriously, complete with disciplinary action against any offenders.
A policy against malicious calls, however, is just your opening move. You then need to follow up with training and communications on the purpose of the hotline and on internal reporting generally. Give examples of what malicious hotline calls are (such as our two examples above) and explain the penalties for making them. Convey the message that, “We know abuses like this can happen, and we’ll be looking for them.”
You could also couple those warnings with more positive messages about the benefits of robust reporting. For example, you could stress that hotlines exist to protect employees who want to do the right thing and to help the company resolve issues – so why would someone want to pollute that company resource with malicious calls?
The most effective message strikes the right balance between negative and positive persuasion to guide people to the desired conclusion. Stress that malicious calls are wrong in themselves, and that a healthy hotline system helps employees and the company alike every day.
Follow through on the message
Despite all your policies, training, and messages, employees might abuse the hotline with malicious calls. So, what else can compliance officers do to quell this headache?
First, remember that the HR team can be a valuable resource, because it has a wealth of data about how employees are treated. You could examine that data for any insights it might provide.
The compliance team needs strong ties with the HR team (and access to HR data!) to help you better distinguish legitimate, misguided, or outright malicious reports.
Second, do treat malicious reports seriously. An employee who deliberately uses the hotline to cause harm is perverting the very purpose of an internal reporting program and eroding the culture of trust that every organization needs to succeed. (Plus, employees making reports about others might expose your company to costly litigation, too.)
The hotline exists as a tool to help the company reduce its compliance risks and improve its corporate culture. Outright malicious calls are probably rare, but compliance officers need to combat that risk anyway with a set of policy, training, and monitoring practices. Then you can get on with the business of investigating legitimate calls and propelling your organization forward.
2026 Guide to Workplace Conduct
Explore the state of workplace conduct issue reports, learn what the data really says about culture, risk and trust, and determine how to best approach your speak-up program in 2026 and beyond.
