Exit interviews can be a useful tool for organizations that are determining how to measure the effectiveness of their compliance program. Many Compliance and Human Resources Departments include exit interviews in their protocols for employee departures. Carrie Kusserow, CHC, CHPC, CCEP, has established and evaluated a number of exit interview programs over the last 15 years. Ms. Kusserow has found that a properly designed exit program can provide early warning signs of potential liability and permit corrective action before a problem escalates. In addition, the exit program may deter departing employees from becoming “whistleblowers” after they have secured new employment and are free from the fear of retribution or retaliation. Affording these employees an opportunity to provide information prior to departure allows them to address grievances and redress any perceived wrongdoing. Ms. Kusserow observes that the most cost effective exit programs are those that separate the exit interview from the standard last day exiting process that includes filling out forms, turning in company property, etc. Departing employees are often preoccupied with the process of leaving the company and may be reluctant to reveal the full and true reasons for leaving. Exit interviews should be conducted as far in advance of the employee’s last day as possible. A live exchange should occur upon exiting rather than a “fill out the form” process, and those conducting the interviews should be properly trained to obtain useful information. Ms. Kusserow offers the following tips for those considering establishing an exit interview program as part of their compliance department performance metrics:
- The exit interview process should primarily be the responsibility of the Human Resources Department, with the Compliance Office having limited influence in the process.
- Keys to achieving success with the exit interview program include determining: (a) who conducts the debriefings; (b) who receives the results; (c) what manner and form the results are received; (d) how the results are used; and (d) who utilizes the results.
- Exit interviews should use open-ended questions to identify issues warranting action.
- The interviewers should ask whether the exiting employee observed any violations of laws, regulations, the Code of Conduct, policies, etc. The Compliance Office should be alerted upon the reporting of any such violation.
- Whenever appropriate, supervisors and/or managers should be contacted regarding relevant exit interview information, as a method to provide constructive feedback.
- Any management, regulatory, or legal issue raised should be addressed before the employee leaves the control of the organization, if possible. Taking corrective action while the individual is still an employee may prevent that person from taking the issues to outside entities such as attorneys, government agencies, media outlets, etc.