Stuff happens

What is better than sending your teenager to a driving class? Also telling her what to do when she gets into a fender bender and gets a ticket. What’s better than that? Role-playing the incident two or three times until she gets it right.

Similarly in the workplace, we should not only teach employees about rules and values, we should also teach them what to do when they observe wrongdoing. Better yet, we should role-play the actual reporting process. It’s easy to say “If you see something, say something.” It’s a lot harder to actually do it, especially if you’ve never done it before.

Most drivers will get into a minor accidents. Most employees will observe wrongdoing. Why not prepare them?


HT to Seth Godin and Mary Gentile.

When companies contribute to employees’ wrongdoing

What are you looking for after you discover wrongdoing in your organization?

Are you just looking for who did it and how they did it? Or perhaps you even try to find out why they did it? But what about looking for all the factors that contributed to the why?

At Flex, those responsible for the new ethics scorecard are doing just that. Part of each investigation is to identify contributing factors over which they have some control. Factors such as defective air conditioning at a site, or poor cafeteria services. Some of us might disregard such factors and consider them irrelevant. But are they, really?

When wrongdoing occurs, we can lay the blame entirely on the employee. Or we can make room for contributing factors created by the company itself. The second option is more plausible, more empowering, and more likely to change the culture in a positive way.

Willful ignorance

Some people never conduct a risk assessment. Others do, but they ignore the findings.

The tragedy of Surfside, Florida could have been avoided. The problems and the solutions were clearly identified. Yet, action was unduly delayed.

If you are not getting your annual physical, if you don’t get your brakes checked, if you don’t have an estate plan, book your appointment today. And, at work, if you don’t conduct a risk assessment for your business, plan one immediately.

Then, perhaps more importantly, act on the findings.

It could save your life.

Send me to the future

If you had access to a time machine today, would you want to go back to the workplace of the ’60s?

What if you are a woman? Or Black? Or transgender?

In a recent interview, Neil deGrasse Tyson said (at 1:52:00) that if you are an oppressed minority and can time travel, there is no time in the past that was better for you than this moment, despite all the problems we are facing today. Go into the future, because the arc of history bends toward justice.

So our mandate is clear. We must work each day to create a world that is more just than yesterday. And by “we”, I mean everybody. Those in the majority just as much, if not more, than those in minorities. Let’s build a world where those born in the next ’60s have no desire to travel back to today.

Involvement is key to commitment

You’ve been asked to work on a project that will impact another function in your company (or more than one function).

You could go at it alone but you know that those impacted will resent your lack of cooperation after you launch your project.

A better approach is to ask them for feedback before you launch. The problem with this approach is that it may be difficult and costly for you to make necessary changes at the tail end.

Better yet is to involve the other functions from the start. Announce your nascent project by email and invite all interested functions to nominate a representative to work with you. Set some gates along the way to ensure that everyone is aligned. Assign key tasks to the functions most impacted by those tasks. These additional steps might appear to slow you down but remember: slow is smooth, and smooth is fast. By involving the right people, you significantly reduce the risk of failure. More importantly, you make allies.

Nothing of significance is ever achieved by a single person.

Has the pandemic caused stress fractures or muscle growth for your company?

Trauma can lead a person to suffer from post-traumatic stress syndrome. Or it can trigger post-traumatic growth.

Companies, being made of people, can also experience both.

The pandemic has been traumatic for many companies. What was its effect on the company you work for? How has it responded to the trauma? Are you bracing for PTSD, or are you poised to emerge stronger?

These questions are important because they can reveal the current state of your compliance culture. If the pandemic has weakened your compliance health, now is the time to take action.

Adapt or die

Do you work for a company that doesn’t give much thought to ethics & compliance? If so, it won’t last much longer.

The only way to change their posture is to change how they look at the world.

Read the homepage of a media outlet every day (I recommend npr.org for the US). Look for a story that points to a change in the world that could affect your company. Discuss this change with your supervisor or another leader, and show them why it would be best to adapt now instead of reacting later.

Do this consistently, and your company will naturally start focussing on ethics & compliance.

In the process, you will also save your company.


HT to Seth Godin

Retaliate at your own risk

The top five editors of a Hong Kong media outlet were arrested yesterday because they published articles calling on foreign agencies to impose sanctions on the Chinese government.

Leaving politics aside, they are being punished by their government for criticizing it. The result, and perhaps the goal of these arrests, will be to silence others who are thinking of making similar claims.

In the corporate world, this is the type of retaliation that we seek to prevent. We know that employees who fear retaliation do not report the wrongdoing they observe. When wrongdoing goes unreported, the best compliance programs collapse.

And when that happens, the collapse of the entire organization is not far behind.

Ethics ambassadors

Your company opens a second office, hundreds of miles away from the original one, with a skeleton crew of ten employees.

No room – and no need – in that new office for a finance person, or a lawyer, or an HR partner.

But you know what that new office could use? A part-time ethics ambassador.

One of these ten employees should act as a liaison between the mothership’s control functions and the new satellite office. Someone to keep the information flowing in both directions. Someone who is responsible for sharing new policies and reminding colleagues to complete their training. Someone who can bring back allegations and concerns to the main office.

If your ethics and compliance function is centralized at headquarters, consider creating a network of ethics ambassadors that are deployed everywhere you do business. My company has nearly 300 of them, and our company is stronger because of that team.

If you’d like to learn how to create such a network, I will be part of a panel of speakers addressing this very topic during an ECI event on June 23.

Hope to see you there!

Creating a safe space

You see your boss do something that appears unethical, but you are not sure.

You are confused because your boss is a good person, one that you can’t imagine doing something wrong.

How comfortable are you to discuss your concern with her?


Now imagine that when you were interviewing for your current job two years ago, you asked your boss if she would welcome you bringing to her attention any behavior of hers that bothered you, and she answered yes. The two of you have not had a similar conversation since.

Are you now more comfortable?


Pretend now that your boss regularly tells you and your colleagues that she expects anyone who has concerns about her behavior or decisions to bring it up to her directly. She says that she will listen to the feedback, no matter how uncomfortable, and that there will never be any retaliation.

How do you feel now?


A culture of compliance is best served when managers make their employees feel safe about speaking up. If you are a manager, don’t expect your employees to speak up without any encouragement from you. Make your commitment to compliance clear and visible.