Fixing the (w)hole

Ethics & Compliance Officers are often required to conduct internal investigations. Most of us are not professional investigators and the process can be overwhelming and intimidating at first. If you are still new at investigations, you should read Jeffrey Klink’s excellent post on the basic 7 steps to follow.

The last step, case evaluation, is of particular interest to me. This is when the business leaders (not the investigators) are supposed to “fix the holes that allowed the misconduct to occur.” For too many leaders, this process involves adding controls or policies to the existing framework. In other words, each time the pipeline is leaking they put some duct tape on the hole. Meanwhile, no one is addressing the fact that perhaps the water pressure is too high.

Here is a question I like to ask myself at the end of an investigation: “What is it about our culture that made our employee think it was OK to do this, or that he would get away with it?” This is a critical question if you believe, as I do, that culture is an outcome of your processes. If you identify the process that created the culture that lead to the misconduct, you can work on the cause of the leak. You’re fixing the hole, and then some.

Is there an element of your culture you don’t like? Find the related process.

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