In 2023, CRICO convened General Counsel and subject matter experts in Risk Management and Human Resources to strategize how to facilitate consistent, time-sensitive, closed-loop processes to address workplace behavior concerns and complaints. The team developed the following best practices recommendations to mitigate EPL risk:
- Define the process: Catalog and document available reporting options, effectively and repeatedly communicate them, and then identify the response team responsible for the complaint.
- Manage a complaint: Provide formal response and follow-up based on established timelines.
- Document the complaint and the response: Create a standard operating procedure for documentation noting file location and compliance and privacy requirements.
- Share findings: Aggregate and analyze complaints to identify trends, vulnerabilities, and potential actions to address risks. Share reports regularly with executive boards and committees.
- Provide training materials: Coding, convening, and putting together training materials, we realized that our insureds needed support to identify and address risky behaviors and worked to implement the PULSE 360 program to enact quality culture change.
CRICO will continue to develop and disseminate recommended best practices through reliable data analysis, member convenings, educational forums, and publications. The organization aims to develop and disseminate at least three suggested guidelines for EPL best practices by the end of 2025.