Cottage industry: third parties who answer calls on Ethics lines (McKesson)

McKesson has made available online its “Comprehensive Compliance Program.” The program has seven elements, one of which is a no-cost telephone number for employees to call to report possible violations. As McKesson states it, “McKesson has established a toll-free EthicsLine, available 24-hours a day, 7 days a week, which can be used to anonymously report violations of the Company’s policies [including its Code of Conduct] or other possible illegal or unethical activity.” As for the law department’s role, “Information from EthicsLine calls is provided to the Company’s compliance attorney for review and appropriate action.”

Note the service provider who actually picks up the phone: “Calls are answered by a third-party communication specialist who is trained to handle calls and forward them to the Company appropriately and confidentially.”

As is evident, there exist niche service providers who answer confidential calls on corporate ethics lines.