by David Vialpando
Casinos are fast-paced, multi-dimensional entertainment centers dependent on a wide variety of professionals – from hospitality staff to cage personnel, table games dealers, slot technicians, security staff, back-office personnel, food and beverage staff and many more. In this complex environment where millions of dollars are transacted daily, it is important that employees have an established process they can employ to voice employment and work condition concerns, as well as report fraud, theft, and other employee actions placing the integrity of gaming and casino assets at risk. Third-party confidential reporting systems are a means by which casinos can maintain transparency and accountability while protecting the identity of employees desiring to report malfeasance.
Most casinos have well-developed employee grievance procedures requiring complaints to be filed with the employee’s supervisor and through the chain of command or reporting issues directly to the human resources (HR) department. These processes work well except when the employee feels their complaint is not being taken seriously, the employee is fearful of retaliation for raising the complaint, or the complaint involves regulatory, public safety, or potential criminal risk.
Some casinos employ a secure complaint receptacle where employees can drop a written note into a management-controlled container for review and follow-up. Unfortunately, this type of manual system is used sporadically at best and not trusted by employees at worst. This type of system also denies access to the complainant for follow-up questions or clarification and collects no data for statistical tracking and complaint accountability.
Several third-party solutions exist for casinos desiring a confidential or anonymous reporting system accessible by a variety of means that employees can trust and interact with as much as necessary to ensure all available information is conveyed, questions answered, and problems resolved. These solutions empower employees to express their concerns without fear of retaliation or adverse impact on their employment, encouraging a more open discussion around sensitive topics. A third-party reporting system can be one of the easiest and most cost-effective internal control systems an organization can implement.
Any number of situations come to mind that render an internal complaint process problematic. If unethical or unlawful behavior involves a supervisor or well-liked colleague, the potential complainant may be reluctant to come forward out of fear that their identity will be revealed by someone within the organization and their professional lives made miserable. If the behavior involves regulatory, safety, or criminal actions, the complainant may desire to confidentially or anonymously alert gaming regulators instead of casino management.
The referral entity for third-party complaint processes, also known as hotlines, can be casino management or the Tribal Gaming Regulatory Agency (TCRA). If the TCRA is the designated referral agency, it is important to remember that gaming regulators typically lack jurisdiction over employment status and most HR matters such as work schedule and attendance issues, compensation complaints, disparate treatment, or abuse of authority. In these cases, the TCRA would refer the complaint to casino management while honoring the complaintant’s request for confidentiality or anonymity. According to the Association of Certified Fraud Examiners, reporting hotlines are the leading method for fraud detection within businesses, over which the TCRA does have authority.
For casino management and TCRA, reporting hotlines provide the following:
- Monitor the business of the casino through the eyes of employees
- Identify potentially harmful issues early and prevent unacceptable behavior
- Ensure regulatory compliance
- Mitigate business risks
Several casinos employ secure online platforms that allow for confidential reporting. These platforms often include features like encrypted submissions, allowing employees to submit their concerns while maintaining privacy. Some solutions enable two-way communication, allowing employees to ask follow-up questions or provide additional information while remaining anonymous. These same platforms enable the casino or TGRA to compile statistics related to complaint categories and disposition through a data management system. Many solutions not only have online reporting capability, but also a 1-800 number employees can call 24/7.
Issues reported by casino employees through reporting hotlines include:
- Criminal misconduct
- Ethics and compliance violations
- Financial issues
- General misconduct
- Harassment and hostility
- Human resources issues
- Breaches of privacy and security
- Safety concerns
Other strategies providing employees with recourse for addressing concerns include employing third-party ombudsman or mediation services, a peer reporting program involving designated employees trained in handling sensitive matters confidentially, or mobile applications allowing employees to report issues from their personal electronic devices.
The predicate to any casino employee complaint process should be a robust whistleblower complaint policy. Employees must be reassured that they will not face retaliation for reporting unethical behavior, misconduct, or employment concerns. A hotline is only effective if employees have confidence in the reporting process and feel protected by their employer.
Casino employees are the first line of defense in detecting fraud, malfeasance, and unethical or unlawful behavior. Designing a robust confidential/anonymous reporting process enhances workplace integrity and reinforces a positive organizational culture of openness and accountability where employees feel valued and heard.
David Vialpando is Executive Director of the Pala Gaming Commission and Vice-Chairman of Tribal Gaming Protection Network. He can be reached by calling (760) 510-4559 or email [email protected].
