I found Adam Turteltaub’s post on the Ethics & Compliance Blog yesterday very exciting.
Turteltaub noticed that the Department of Justice, in its new guidance to prosecutors, used the word “process” 29 times and practically ignored the words “law” and “legal”. Effectively, the DOJ is telling its prosecutors that they need to focus on how organizations conduct their business.
This is exciting because it will change corporate culture in America. For years, organizations have been puzzled by the Sentencing Guidelines‘ requirement that companies “promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.” Companies have asked “What is culture? How do you change it?” Research demonstrating that culture is an outcome of our processes remains largely unread by the business community because it is often buried in academic papers.
Whether it was intentional or not, the DOJ has now told business organizations how to change their culture for the better. There has never been a better time for ethical leaders to tackle this issue.