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Essay · By Erin Glover, SHRM-SCP · September 28, 2026 · 9 min read

Who Is Accountable for Accountability?

Accountability is complicated, and no policy can give someone the confidence to act in a tense moment. What employers can do is make raising a concern the easiest decision someone makes that day.

Think about the last time you saw something at work that didn’t sit right with you. Maybe it was a comment in a meeting, a joke that went too far, or a message in a group chat that everyone scrolled past. Did you say something? Did anyone? If not, you’re in good company.

Recent news has me thinking a lot about accountability. A former Cornell student has filed a lawsuit alleging that seven fraternity members assaulted her in 2024. The allegations have not been proven in court, but one detail stays with me. According to the suit, one member posted to the fraternity’s group chat that night, inviting others upstairs. Far more than seven people could have seen it. Did anyone in the chat even call out their fellow brothers? The complaint, as reported, does not describe anyone who did.

This is a classic example of the bystander effect, and the force behind it is diffusion of responsibility. In a 1968 experiment, psychologists John Darley and Bibb LatanĂ© had students talk over an intercom while one of them appeared to have a seizure. When students believed they were the only one listening, 85% went for help. When they believed four other people could hear it too, only 31% did. Each student assumed someone else was already handling it, and the more people who could hear, the easier that assumption became. Your company has group chats too: a Teams channel, a Slack thread, a group text for second shift. Picture a message in one of them that crosses a line, read by twenty people who keep scrolling. The EEOC’s task force on workplace harassment found that about 70% of people who experience harassment never tell a supervisor.

All of this made me ask a bigger question: who is accountable for accountability? My answer is everyone, and it’s the employer’s job to make that true. If you want a culture of accountability, everyone needs to feel empowered to hold others accountable, and they need to know it’s their job.

Accountability is complicated, and no policy can give someone in a tense situation the confidence and clarity to act in the moment. What you can do is make the process as simple as possible. The best way to protect your organization is to make raising a concern the easiest decision someone makes that day. Here are four ways to do it.

1. Make it everyone’s problem

The first question people ask themselves is whether it’s their place to say anything. Safety culture shows how to answer it. In a strong safety program, anyone can stop the work when they see something dangerous, and OSHA’s recommended practices start with two things: leadership commitment and worker participation. Stop-work authority belongs to everyone, and nobody has to wonder whether it’s their place to use it.

Misconduct needs the same clarity. Write it into your policies and say it out loud: every employee is expected to raise concerns, and every manager is required to act on them. Then train people on what misconduct actually looks like in your workplace, with real examples. A pattern of comments or a manager who always “jokes” with the same employee can scroll right past in a busy week, and when everyone around you stays quiet, you start to wonder whether you’re overreacting. Naming unacceptable behavior ahead of time means nobody has to guess where the line is. We all have a responsibility to say something when we see something, so make “see something, say something” a team norm. Talk about it in team meetings, thank people who speak up, and treat raising a concern as part of doing the job well.

2. Make it easy to act

Once people know it’s their place, they need to know how to act and have the energy to follow through. Speaking up takes more decisions than it looks like. Darley and LatanĂ© also found that a person has to notice the problem, recognize it as a problem, decide it’s their responsibility, know what to do, and then choose to act. Each of those decisions takes energy, and people are least likely to make them when they have the least to give: at the end of a double shift, during a crunch week, or after a night without enough sleep. Research on sleep and ethics backs this up. In studies by Christopher Barnes and his colleagues, employees who slept less were more likely to behave unethically, and mental fatigue explained the connection.

That makes overwork a risk well beyond missed deadlines and sloppy work. Tired employees are less likely to use their best judgment, whether that means following your code of conduct themselves or speaking up when someone else doesn’t. Every decision you settle ahead of time is one less decision a tired person has to make in the moment.

Timing matters, too. Before a busy season, a big launch, or a stretch of overtime, take a few minutes to remind your team what’s expected and how to raise a concern, the same way a good supervisor runs a safety huddle before a hard job. A reminder someone heard on Monday is much easier to act on than a policy they signed at orientation, especially when they’re exhausted on Friday.

You can also cut down on how many decisions your people have to make in a day. Lean methods, which many manufacturers already use, rely on standard work and organized, visual workspaces so people spend less energy figuring out how to do the job. The same idea works for knowledge workers: clear priorities, templates for recurring tasks, fewer unnecessary meetings, and a manager who decides what matters most this week. When the routine decisions are already made, people have more energy left for the ones that matter.

Many people stay quiet because they don’t know what to say or where to go. Your reporting process should be simple enough that any employee can describe it from memory: who to tell, how to tell them, and what happens next. Give people more than one path, so no one has to bring a concern to the person causing it.

For a company of 50 or 100 people, simple can look like this: a dedicated phone number that takes calls and texts, an anonymous online form, and two named people who check both every business day, one of whom is someone other than the owner. Post the number and the form by the time clock and in the break room, promise a response within a set number of days, and track every concern from the day it comes in to the day it’s closed.

It also helps to teach people that speaking up comes in more than one form. The nonprofit Right To Be teaches bystanders five options, known as the 5Ds: distract, delegate, document, delay, and direct. Speaking up can mean interrupting the moment, bringing in a manager, writing down what you saw, checking in with the person afterward, or naming the behavior when it’s safe to do so. Once people know they have options beyond a confrontation, the gap between seeing something and saying something gets smaller.

3. Close the loop

After someone speaks up, they want to know whether anything will happen and whether they’ll pay a price for it. This is where many employers lose people. In a study by researchers at New York University, 85% of the 40 employees they interviewed described a time they felt unable to raise an important concern with their boss. Among the most common reasons were a belief that speaking up wouldn’t change anything and a fear of retaliation.

Those fears are grounded in reality. In the Ethics & Compliance Initiative’s 2023 survey of more than 70,000 employees in 42 countries, 65% had observed misconduct in the past year, and 72% of those employees reported it. Of the people who reported it, 46% experienced retaliation. Researchers James Detert and Amy Edmondson found that people speak up when they believe it won’t put them at risk and won’t be a waste of their time. Every concern that disappears without a response chips away at both beliefs.

A good process has a feedback loop. Acknowledge the concern quickly, look into it, resolve it, and tell the person who raised it that it was handled, even when you can’t share every detail. Then watch for retaliation, because the next person is watching what happened to the last one.

Closing the loop also means asking about the people who didn’t speak up. When you interview witnesses who saw something and didn’t act, ask them why, and make it a standard question in every investigation. The question worth asking is why only one person raised a concern when ten people saw it. Ask it the way a good safety team reviews a near miss, to find out what got in the way, so the answers help you fix the process and nobody walks away afraid of the next interview.

How you close a concern matters as much as whether you do. Cornell’s statement cited federal privacy law, which is a real limit, but the public filled in the rest from the lawsuit: two of the seven were reportedly expelled, and others received suspensions, workshops, or essays, while she left school. Many women know the frustration of watching the consequences for the accused land more lightly than the consequences for the person who came forward, and it only discourages the next person from coming forward. What I recommend to any employer is the front page news test. If it got out that you handled a concern a specific way, could you defend it? Or would you be embarrassed by your response? Assume anything could become public.

4. Model calling it out

Finally, people watch whether their leaders mean it. If senior leaders walk past unsafe behavior, everyone learns how much safety really matters. Misconduct works the same way, and the hardest test is the top performer. You have a finding against them, and you’re afraid of losing them. I understand why owners hesitate. They still have to be held accountable to the same standards and policies as everyone else. Not holding one person accountable normalizes the behavior, and it weakens your position the next time you need to hold someone else accountable for the same thing.

Who you promote sends the same message. McKinsey and Lean In’s 2025 research found that white men make up 32% of entry-level corporate employees and 56% of the C-suite, and when the top of an organization all looks the same, it can become a fraternity with a payroll that protects its own.

If you’re a man reading this, you have more power here than you may realize. Research shows that when men call out sexist behavior, they’re taken more seriously and are less likely to be dismissed as complaining than women who say the same thing. A culture of accountability needs men who are willing to be the one in the chat who says, “This isn’t okay.”

Modeling also means dealing with what you inherit. Earlier this month, the mayor of New York City released about 170,000 pages of the city’s records on its response to 9/11. The records show that officials in 2001 understood the dangers at Ground Zero while publicly assuring residents and first responders that the air was safe. Those records stayed out of public view for 25 years, and each administration that followed left the question for the next one. The current mayor stopped the pattern by bringing it to light. If you bought a business, took over from a founder, or inherited a team, a problem becomes yours the day you learn about it.

One thing for Monday

The person at the top is accountable for accountability, and the way you meet that responsibility is by building it into how your company works, so it never depends on one brave person in a group chat. Look at your process for reporting and resolving concerns and ask four questions. Does every employee know it’s their job to speak up? Do they know exactly how? Does every concern get closed out, with the person who raised it hearing back? Are your leaders, including you, modeling it, even when the concern involves your top performer? All four come down to one question: how easy is it to raise a concern at your company? If you don’t have a process yet, I recommend putting one together. Send me an email at erin@gloverco.ai if you’d like my help!

Sources

The author

Want help building a reporting process people will actually use?

Erin Glover, SHRM-SCP, founder of Glover & Co., Newington, Connecticut

If this raised a question about how concerns get raised at your company, I’d love to hear what you’re working on.

Educational, not legal advice. Seek counsel if you would like a legal opinion. Verified 28 September 2026.

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