The whole truth

My advice to employees who report wrongdoing to their ethics and compliance officer: tell the whole truth.

If you leave something out, it will affect your credibility. Once your credibility is affected, nothing you said, or will say, can be taken for granted.

The ethics officer you hoped would be your partner in righting a wrong will now have to doubt you every step of the way. Furthermore, she may lose some of her appetite to fight your fight.

If some of the facts are not helping your case, you should still disclose them up front. Don’t let your ethics officer find out from someone else.

Bad ideas

I probably come up with 10 bad ideas before I have a good one (if I’m generous to myself).

Chances are, our colleagues do no better. So for good ideas to surface at work, we need to welcome bad ideas.

What is your organization’s appetite for bad ideas? What happens to people when an idea, a project, or a big initiative doesn’t work? In some organizations, they throw a party to celebrate the lessons learned. In others, heads roll.

How safe is it to have bad ideas where you work?

Show how much you care

If you ever faced a personal crisis, you remember how unhelpful it was when a friend said “Let me know if I can help.”

Well-intentioned, but unhelpful. It just added on more task on your overwhelming list. What you needed was a friend who said “Our family is going out to dinner and we’ll take your kids along so you can have a couple hours of quiet time.”

At work, when your team is struggling to meet a critical objective (financial or otherwise), asking them to let you know if they need help is equally unhelpful. Unhelpful and potentially dangerous. They might think that you care about the objective but not about how they will meet it. What they need to hear from you is “Let’s get in the conference room and figure out exactly how we are going to meet this goal the right way.”

How good ideas surface

I don’t know who said it first, but having a healthy speak-up culture does not only serve the compliance function.

When employees feel comfortable enough to raise concerns, they usually feel comfortable enough to share good ideas.

A good idea often brings disagreement. It disagrees with the old way of doing things, and some people are likely to disagree with the new idea.

We need organizations that can live with disagreements. As the world changes (and it always does), the faster new ideas are welcome, the more resilient is the organization.

Building a speak-up culture may be the most important thing we can work on.

HT to Seth Godin.


When two companies announce a merger, competition and securities laws prevent them from collaborating in almost every way until the merger is closed.

Ethics and compliance professionals are one exception. These pros from both companies are allowed to collaborate pre-merger, so that on Day One the new company can have a unified set of values, a common code of conduct, a standard way of reporting and escalating allegations of misconduct — among other things.

This is allowed because E&C professionals from different firms don’t compete, even within the same industry. The nature of our work is intended to be cooperative. Yet, so few of us actually reach out to one another to learn and grow.

If antitrust laws allow us to collaborate pre-merger, why aren’t we collaborating even more on a regular day?

Give and take

Are you an ethics and compliance officer tackling something for the first time? A code, a policy, a training, an audit – anything?

The rest of us are here for you. Chances are, hundreds of us have done the very same thing before, and we could save you a ton of hassle. All it takes is a few minutes on LinkedIn or Twitter or ECI Connect to ask for help.

But if what you’re doing is truly novel and has never been done, then please share the learnings with the rest of us.

All of us are smarter than anyone of us.

What’s in a name?

The World Health Organization just updated its guidelines to name newly discovered diseases, viruses and variants.

The goal is to avoid negative impact on people, places, tourism and trade. It turns out that when you give a virus the name of, say, “Spanish Flu”, it doesn’t do much good for Spain and Spaniards.

Do you work in an organization where names are given to special compliance initiatives or projects? Do you use vague code names like “Project Maple”, or specific last names, geographic locations, or business unit names? If the latter, have you considered the possible negative impact on the employees covered by these labels?

If they knew

What would your mother think?

What if it were on the front page of the newspaper?

These two integrity tests apply strong emotional pressure.

But here’s a more subtle test, one that we can use for most interactions:

If the people you’re interacting with discover what you already know, will they be glad that they did what you asked them to?

Seth Godin, The Practice, #36