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Whistleblowers can save companies a lot of money and avert a lot of trouble – if they can get their message across. Zora Ledergerber is there to help.

Founder of Integrity Line: Zora Ledergerber

Graham Peaker had been getting a lot of emails that led him to some explosive information. The European football championship had just finished. The bookmakers reckoned that bets amounting to about €70bn ($70bn) were placed on the tournament’s 51 games. The emails alerted Peaker to allegations of fixed matches, bribery and betting fraud. He evaluated each message, checking to see whether it tallied with ongoing investigations. Peaker is the lead investigator for the governing body of European football, Uefa, exposing match-fixing and betting fraud. Before revealing his information, says Parker, an informant will ask himself three questions: Who do I tell? Who can I trust? Who can ensure nothing happens to me?

Zora Ledergerber can help with all three. She set up Integrity Line, based in Zurich, which has developed a system that is one of Peaker’s key sources of information. She receives messages from whistleblowers via an online platform, encrypts the information and sends it to where it should go – and ensures the source remains anonymous. “We link whistleblowers to companies,” says Ledergerber, “but in a way that ensures the informant has nothing to fear.”

Integrity Line was founded in 2009. As well as Uefa, Switzerland’s postal service and federal police have also installed it. The firm now has 10 staff looking after about 30 clients, including some well-known companies.

“We link whistleblowers to companies but in a way that ensures the informant has nothing to fear.”
Zora Ledergerber

The keen interest is no fluke; the public has become more sensitive about misdeeds in the business world. The US has been pressuring other countries to take a harder line on corruption for some years. As the relevant laws in the US are stricter than in many other countries, American firms often suffer a competitive disadvantage, which irks Washington. Changes are afoot in Europe, too; since 2014 financial institutions in the European Union have had to set up internal whistleblower systems. Germany’s financial supervisory authority, BaFin, has been running one for external informants since July.

These systems can pay dividends, because more and more companies are being caught out in illegal activities. Volkswagen’s emissions scandal means the company faces fines running into billions. In 2008, Siemens was hit by a penalty of more than €1bn after one of the biggest industrial corruption scandals in German history. And the Swiss bank UBS had to pay about €36m because one of its traders gambled away billions in illicit dealings.

But fines are one thing, reputational damage is another. Nobody wants to do business with a company linked to criminal activity. It takes years for affected firms to shrug off the taint.

What do all these cases have in common? There were always people who knew. Bosses, subordinates, colleagues, secretaries, book-keepers – somebody knew, somebody heard something or suspected something. As Uefa’s Peaker puts it: “The information is out there; we just have to get our hands on it.”

Message to staff: spill the beans!

Uefa decided in 2009 to take a tougher line on fraud. Several men were then in court in Bochum, western Germany, accused of fixing 270 soccer matches throughout Europe. The trial resulted in prison sentences. But more remarkable than the verdict was the extent of the fraud – and how thoroughly it had been organised. Players, coaches and referees had been bribed in Germany, Austria, Switzerland, China, Turkey, Bosnia-Herzegovina, Croatia, Slovenia, Hungary and Belgium. It involved national soccer league games, but also matches in Uefa’s Europa and Champions Leagues. “After that it was clear. That’s enough. We have to do more than we have in the past,” says Peaker.

In 2010 Integrity Line’s whistleblower system was set up for players, referees and coaches. Now anyone can use it. The home page asks the user what is involved: “Match-fixing. Bribery. Betting on sport.” The next page offers text fields in which to describe the incident, enter the teams involved, the date of the match and type of competition. Then come the key questions: Is there any proof to confirm your information? And if so, state what it is. When the whistleblowers have submitted their reports, they receive a case number. That enables them to log in again on the server to check for any queries. They can still remain anonymous as their IP addresses – which identify the computer used to send the information – are not recorded.

“Communicating with the whistleblowers can be very informative. They often have even more information.”
Graham Peaker, Uefa

Integrity Line vouches for anonymity: confidentiality is the company's business model. The report lands on an encrypted server in a secure place in Switzerland and Peaker immediately receives an email that a new report has arrived for him. He is not allowed to comment on individual allegations. “They are mostly like jigsaw pieces,” he says, “that we can match into ongoing investigations.” The confidential feedback channel is a great help, too. “Communicating with the whistleblowers can be very informative. They often have even more information.”

To publicise the system, he travels around Europe talking to players, referees and coaches, and encouraging them to report attempts at bribery. Uefa has also set up a phone number for whistleblowers via Integrity Line and a free app to report information.

The system works on the same lines for other Integrity Line clients. But international companies usually want to contact their own staff. They are keen to find out early if something is not right. “There’s usually less damage the sooner you step in,” says Ledergerber. “And less risk of a leak.”

Ledergerber studied law in Zurich and Paris, but nearly dropped out just before her exams. She did not like memorising dry legal texts, or the prospect of life as a lawyer. But she struggled on, and after graduating got a job in Bosnia-Herzegovina working for a civilian unit of the Swiss army. She was the contact for members of the Organisation for Security and Co-operation in Europe (OSCE). After that she spent three years as managing director in Switzerland of the anti-corruption organisation Transparency International before becoming a consultant at the Basel Institute on Governance, advising governments all over the world on the fight against corruption. Her doctoral dissertation was entitled Whistleblowing as a Means to Combat Corruption.

Zora Ledergerber

Ledergerber always wanted to set up something of her own and the time seemed ripe for a go-between for whistleblowers. She started in October 2009. She had hardly any money. She had written her dissertation in Café Plüsch in Zurich and she set up her first office in the Restaurant Bohemia. The developer took six months to create a program to meet her requirements: “It didn’t look much like what we have now.” And she had little idea of the difficulties she would face in setting things up either.

As the number of clients grew, so did the demands on the system. For instance, there was a request to be able to phone in information, because internet connections were not very good in some countries. Ledergerber appointed a call centre, but was not satisfied with the results. Now anyone can leave a voicemail. Contacts with lawyers can also be arranged, if someone wants to make a personal statement.

And then there are the data-protection rules. The Integrity Line system can be accessed from 150 countries and in 30 languages. Its customers have about five million staff, customers and suppliers all together – every one a potential whistleblower. That also means that 150 different sets of national data-protection regulations have to be complied with. Ledergerber had to find a law firm in every country to clarify questions on handling data.

No state secrets from China

As the work progressed, she discovered a lot about the world. In France her organisation’s system has to be registered with the data-protection authority. In Germany it has to be agreed with a company’s works council. In Peru, no one is allowed to make anonymous accusations against a colleague, because everyone has the right to know their accuser and the allegation.

But those are trivial matters compared with China, where it is forbidden to transmit state secrets abroad electronically. That involves clarifying what is a state secret, and it means that Ledergerber has to include an extra question to the whistleblower: “Are you going to reveal a state secret in your report?” The informant can then tick yes or no. For yes, a message pops up: “Sorry, we are not allowed to accept your information.”

“The companies really have to want to do it, and seriously get to work on the cases, otherwise it’s no use."
Zora Ledergerber

Russia makes life difficult, too. A new law stipulates that information about Russian citizens must first be stored on Russian servers before being sent to foreign devices. So Ledergerber must again ask another question: “Does your information affect Russian citizens?” If the answer is yes, the message is first deposited on a server in Russia. “That is a back door for snooping,” says Ledergerber, “but the whistleblower still remains anonymous.”

Regarding individual cases, she only has statistics to go on. She cannot look into the system. She knows that about 50% of the internal company messages are about working conditions – the office is too small, the atmosphere at work is bad, there is a climate of fear. The other half comprises evidence of potentially criminal offences that must be investigated. She does not know how often that happens. It is clear that a system such as Integrity Line is not enough on its own. “The companies really have to want to do it, and seriously get to work on the cases, otherwise it’s no use,” says Ledergerber. Critics accuse Uefa of only half-heartedly tackling corruption. And while Volkswagen has an ombudsman, it was little help in the emissions scandal.

Can this system be abused? Someone might attempt to accuse an unpopular colleague of an offence. Ledergerber says that does happen. “A customer recently did an evaluation. In 150 reported cases, there was just one false accusation.” So the risk is limited.