Exit interviews: Just going through the motions?

Exit interviews are a very useful tool in a compliance program that all companies should consider.  They can be viewed as part of your efforts to evaluate and assess the compliance program – a step called for in the Sentencing Guidelines standards and also expected by DOJ. They can also indicate potential areas of compliance risk in the company.

Interviews should not be perfunctory.

I recall reading an article in the Wall Street Journal that delved into the subject of exit interviews and provided very useful insights. (Allison Pohle, “Should You Be Honest in the Exit Interview?” (WSJ 8/9/21 p. A9)).  If a company is smart and serious about compliance and ethics it will include questions related to culture and compliance in exit interviews.  But this should not just be a perfunctory exercise, where you get HR to agree to do it and then walk away. 

One reference in the article brings this to life, where interviewees said the exit interviews “seemed perfunctory, as though human-resources personnel were going through the motions.”  How do you know whether this is the case in your company or not?  You may be wasting an important opportunity to gather valuable input for your compliance programs.  Exit interviews should be considered one of the measurement tools to see how well your compliance program is working.  But like everything else in your program, the exit interviews themselves also need to be evaluated. 

Will people be honest?

Another aspect of the article addressed how honest people will be in these interviews.  Of course, some interviewees might not care since they are leaving.  Others might still fear retaliation. The article quotes experts explaining that the interviewers should be respectful in their approaches, since feedback does not need to be hostile; criticism can be constructive.  As for motivation, people leaving companies sometimes noted that they cared about former co-workers and were speaking up for them. 

Using questions that get better responses.

There is also the question of how you ask questions.  SCCE’s Gerry Zack, writing in the February 2022 Compliance and Ethics Professional (“The value of exit interviews”), discussed the importance of exit interviews. He offered a very insightful suggestion for what to ask in these interviews.  Aside from asking if the departing employee knows of any improper conduct, consider also asking the person “how their supervisors handled it when workers were found to be violating rules.”

This type of question does not give the person the easy out of a “yes” or “no” answer, and it is not credible to believe a supervisor has never seen anyone do anything wrong. Open-ended questions can lead to more thoughtful responses, and lead to a broader discussion.  Once you start down this route you may get more significant information, including instances where there are cultural or organizational problems.

Exit interviews in the field

In a large company there is the question of how you address exit interviews if you have multiple locations and business units.  Here we touch again the value of field compliance managers or compliance ambassadors.  This is a possible task that these managers could be trained to handle.  Of course, the perfect here should not be the enemy of the good.  In a company with significant turnover in employees it may not be practical to reach everyone, but you can still try to reach as many as you can.  It may not be a perfect solution, but having the ability to reach at least a good sample of employees throughout the company can still give you useful input on how well the compliance program is working.

Are surveys a substitute?  Online exit interviews?

Having said that worrying about perfection should not stop you from doing what you can, we should still be careful in looking for quick or easy answers.  Employee surveys certainly have value, but they are just one tool and not a total solution.  Exit interviews occur at a point where employee motivation is likely very different from when a standard company-wide survey takes place.  Also, surveys tend to be somewhat shallow; a survey reaching thousands of employees is not likely to dig deeply.  But a live employee interview may expose questionable activities that might not surface on surveys.

This same point can apply for online exit interviews.  It is better than nothing and it may allow comprehensive reach, but there will likely never be a substitute for face-to-face discussions by an empathetic compliance person. Again, a useful compromise might be to use both tools, so that at least some exits include live interviews, with an online form used for comprehensive coverage when live interviews are not practical.

Compliance professionals should not ignore this potential tool in their compliance work.  It can provide another important source of input about what is happening in the company.