Thanks Jan! Could you elaborate on the first point specifically? Just from a cursory look at the linked doc, the first three suggestions seem to have few drawbacks to me, and seem to constitute good practice for a charitable movement.
Set up whistleblower protection schemes for members of EA organisations
Transparent listing of funding sources on each website of each institution
Detailed and comprehensive conflict of interest reporting in grant giving
I’ll note that many EA orgs already have whistleblower protection policies in place and that there are also various whistleblowing protection laws in many jurisdictions (including the US and the UK) which I assume any EA affiliated organization or employee would have to follow.
I can’t speak to orgs, but the scope of legal protection for whistleblowing protection for US private employees is quite narrow—I think people are calling for something much more robust. Also, I believe those protections often only cover an organization’s actions against current employees—not non-employer actions like blacklisting the whistleblower against receiving grants or trashing them to potential future employers.
Unfortunately not in detail - it’s a lot of work to go through the whole list and comment on every proposal. My claim is not ‘every item on the list is wrong’, but ‘the list is wrong on average’ so commenting on three items does not solve possible disagreement.
To discuss something object-level, let’s look at the first one
’Whistleblower protection schemes’ sound like a good proposal on paper, but the devil is in detail:
1. Actually, at least in the EU and UK, whistleblowers pointing out things like fraud or illegal stuff are protected by the law. The protection offered by law is probably stronger than an internal org policy for some cases, and does not apply in other cases. Also, in some countries there are regulations what whistleblower protections you should have in place—I assume orgs do follow it where it applies. 2. Many orgs where it makes sense have some policies/​systems in this direction, but not necessarily under the name of ‘whistleblower protection’. 3. Majority of EA orgs are orgs which are quite small. I don’t think if you have a team of e.g. four people, having a whistleblower protection scheme works the same way as in org with four hundred people. In my view, what actually often makes more sense, is having external contacts for all sort of issues—e.g. the community health team. 4. Overall, I think often the worst situation is when you have a system which seemingly does something, but actually does not. For example: a campus mental health support system which is actually not qualified to help with mental health problems, but keeps track who reached out to them, is probably worse than nothing.
My bottom line is something like … ‘whistleblower protection scheme’ may be good to implement in some cases, and some orgs have them. But it is too bureaucratic in other cases. Blanket policy requiring every org to have a formal scheme, no matter what the size or circumstances, seems bad.
The Cremer document mixes two different types of whistleblower policies: protection and incentives. Protection is about trying to ensure that organisations do not disincentivize employees or other insiders from trying to address illegal/​undesired activities of the organisation through for example threats or punishments. Whistleblower incentives are about incentivizing insiders to address illegal/​undesired activities.
The recent EU whistleblowing directive for example is a rather complex piece of legislation that aims to protect whistleblowers from e.g. being fired by their employers in some situations.
The US SEC whistleblowing program on the other hand incentivizes whistleblowing by providing financial awards, some 10-30% of sanctions collected, for information that leads to significant findings. This policy, for the US, has a quickly estimated return of 5-10x through first order effects, and possibly many times that in second order effects through stopping fraud and reducing the expected value of fraud in general. The SEC gives several awards each month. A report about the program is available here for those interested.
Whistleblower protections tend to be more bureaucratic and are already covered by US and EU legislation to such an extent that improving them seems difficult. Whistleblower incentive mechanisms meanwhile seem much more worthwhile to investigate, because such a mechanism could be operated by a small centralized function without adding any new bureaucracy to existing organisations. I suspect that even a minimal whistleblower incentive* mechanism would reduce risks and increase trust within the EA diaspora by increasing the probability that we become aware of risky situations before they snowball into larger crises.
(*incentives here might not mean financial awards like in the SEC program, but something like helping the whistleblower find a new job, or taking the responsibility for investigating the information further instead of expecting the whistleblower to do it. I’d guess that most whistleblowing reports in EA, if any, would involve junior workers who are afraid of losing their income or status in the community, or simply do not have the energy, network, or skills to address the issue directly themselves.)
Thanks Jan! Could you elaborate on the first point specifically? Just from a cursory look at the linked doc, the first three suggestions seem to have few drawbacks to me, and seem to constitute good practice for a charitable movement.
I’ll note that many EA orgs already have whistleblower protection policies in place and that there are also various whistleblowing protection laws in many jurisdictions (including the US and the UK) which I assume any EA affiliated organization or employee would have to follow.
I can’t speak to orgs, but the scope of legal protection for whistleblowing protection for US private employees is quite narrow—I think people are calling for something much more robust. Also, I believe those protections often only cover an organization’s actions against current employees—not non-employer actions like blacklisting the whistleblower against receiving grants or trashing them to potential future employers.
Unfortunately not in detail - it’s a lot of work to go through the whole list and comment on every proposal. My claim is not ‘every item on the list is wrong’, but ‘the list is wrong on average’ so commenting on three items does not solve possible disagreement.
To discuss something object-level, let’s look at the first one
’Whistleblower protection schemes’ sound like a good proposal on paper, but the devil is in detail:
1. Actually, at least in the EU and UK, whistleblowers pointing out things like fraud or illegal stuff are protected by the law. The protection offered by law is probably stronger than an internal org policy for some cases, and does not apply in other cases. Also, in some countries there are regulations what whistleblower protections you should have in place—I assume orgs do follow it where it applies.
2. Many orgs where it makes sense have some policies/​systems in this direction, but not necessarily under the name of ‘whistleblower protection’.
3. Majority of EA orgs are orgs which are quite small. I don’t think if you have a team of e.g. four people, having a whistleblower protection scheme works the same way as in org with four hundred people. In my view, what actually often makes more sense, is having external contacts for all sort of issues—e.g. the community health team.
4. Overall, I think often the worst situation is when you have a system which seemingly does something, but actually does not. For example: a campus mental health support system which is actually not qualified to help with mental health problems, but keeps track who reached out to them, is probably worse than nothing.
My bottom line is something like … ‘whistleblower protection scheme’ may be good to implement in some cases, and some orgs have them. But it is too bureaucratic in other cases. Blanket policy requiring every org to have a formal scheme, no matter what the size or circumstances, seems bad.
The Cremer document mixes two different types of whistleblower policies: protection and incentives. Protection is about trying to ensure that organisations do not disincentivize employees or other insiders from trying to address illegal/​undesired activities of the organisation through for example threats or punishments. Whistleblower incentives are about incentivizing insiders to address illegal/​undesired activities.
The recent EU whistleblowing directive for example is a rather complex piece of legislation that aims to protect whistleblowers from e.g. being fired by their employers in some situations.
The US SEC whistleblowing program on the other hand incentivizes whistleblowing by providing financial awards, some 10-30% of sanctions collected, for information that leads to significant findings. This policy, for the US, has a quickly estimated return of 5-10x through first order effects, and possibly many times that in second order effects through stopping fraud and reducing the expected value of fraud in general. The SEC gives several awards each month. A report about the program is available here for those interested.
Whistleblower protections tend to be more bureaucratic and are already covered by US and EU legislation to such an extent that improving them seems difficult. Whistleblower incentive mechanisms meanwhile seem much more worthwhile to investigate, because such a mechanism could be operated by a small centralized function without adding any new bureaucracy to existing organisations. I suspect that even a minimal whistleblower incentive* mechanism would reduce risks and increase trust within the EA diaspora by increasing the probability that we become aware of risky situations before they snowball into larger crises.
(*incentives here might not mean financial awards like in the SEC program, but something like helping the whistleblower find a new job, or taking the responsibility for investigating the information further instead of expecting the whistleblower to do it. I’d guess that most whistleblowing reports in EA, if any, would involve junior workers who are afraid of losing their income or status in the community, or simply do not have the energy, network, or skills to address the issue directly themselves.)