The original internet was in the bibliography of books.

You read something interesting in a book, followed the footnote to the bibliography, then went to read that book. So on and so forth. You actually learned something.

The real internet has made this process easier. Yet, most people only read headlines. Headlines claiming that climate change is not real, that vaccinations are bad for you, that Elvis is still alive, and that the Earth is flat. And people Tweet those headlines, and re-Tweet them.

Next time you come across one of these articles, look for the source links (i.e. the bibliography). You probably won’t find any. If you do, you’ll soon see how unreliable they are, pointing only to other articles without sources.

Picture this factory of 500 employees, somewhere in the U.S.

In the last two years, more than 80 employees were injured by a specific machine, some very seriously. One employee even died.

Many of the employees are not using the machine correctly. Some don’t even wear the protective equipment provided by the company. Strangely, when the company decided to impose safety training and threatened to fire employees not wearing the protective equipment, some employees protested, claiming it was their right to get injured if they wanted to.

Of course, that factory doesn’t exist.

Of course, it’s an allegory about the pandemic.

As another strange year comes to a close, this is my wish for all my readers for 2022: May you be happy, may you be healthy, may you be at peace.

According to the Committee to Protect Journalists, in 2021 so far, 293 journalists were put in prison because of their job (50 of them in China) and 24 were killed (source).

If you were offered a journalist job in China, might you hesitate?

Let’s imagine a company where, this year, 293 employees were demoted after reporting their boss’s wrongdoing, and 24 were terminated.

If you were offered a job there, might you hesitate?

Imagine an old-fashioned weight scale.

Now imagine using it to measure who your compliance training is for.

On one side, you would place weights on behalf of your employees, measuring your desire to help them do their job compliantly.

On the other side, you would place weights measuring your desire to meet the enforcement authorities’ requirements, to track completions, to automate reminders, to please your board, etc.

Which way would the scale tip?

The employee who reports wrongdoing should receive an answer to two questions after the investigation:

1. Did you take action against the wrongdoer?
2. Did you change the system or process that contributed to the wrongdoing?

Too often, the second question is ignored, both by the company and the victim.

Which is why the same wrongdoing happens over and over again.

Just before the pandemic, a German flutist experimented with the idea of “one-to-one concerts.”

One artist. One audience member.

When the pandemic hit, it became immediately clear that these concerts could go on. Not only were the performances immune to COVID-19, they also fed that hunger for connection we all felt. There have now been concerts across Europe, Asia, Australia and the US.

An art reporter attended one of these performances in Brooklyn earlier this year. Sitting atop a building, he listened to a solo viola playing Bach and described it as “almost overwhelming, emotionally and musically.” He later said “It may have been only 10 minutes, but I’ll be thinking about my One-to-One Concert […] for a long time to come.” (I recommend you listen to the 3-minute audio report.)

This concept reminded me of my choice to introduce my company’s ethics & compliance program to each new employee during one-on-one meetings, rather than join other functions who batch new-employee training once every quarter. Let me rush into saying that I do not claim to be a virtuoso at what I do, or that new employees have an emotionally overwhelming experience listening me describe our corporate values! But I do believe that employees are more likely to reach out to me when they have ethical concerns later on if we have met one-on-one soon after they’ve joined. And I have been told, by several employees, sometime years after we first met, how impressed they were to have been invited to this one-on-one alone-time.

Most artists can’t survive on one-to-one concerts. Their need to perform in front of larger audiences is real.

The same need is not necessarily present in ethical leadership.

Some employees do not have to make any decisions on the job.

Until they do.

The employee that simply needs to stock the shelves at the grocery store might one day notice that the receiving supervisor is taking small bribes from suppliers who want priority in getting their trucks unloaded. That employee with a “no-decision job” now has a decision to make.

Do you have such employees working for you? Do you share your company values with them? Do you provide ethical decision-making training to them? Do you tell them about your reporting channels?

Low-level, no-decision employees are often front-line employees. Which means they are close to the customers, to the suppliers, even to the competitors. These interactions can be risky.

Removing decision-making from employees can reduce some risks, but it can also create others.

If you live in the US, I hope you were able to vote on this Election Day.

Consider the other “votes” you will cast today:

• The type of work you will do
• The employer you will sell your time to
• The project you will sign up for
• The colleague you will partner with

You can change how you vote every day. If you question the work you do, or who you do it for or with, you can vote differently. Small votes lead to small changes, and those lead to big changes.

A year from now, you’ll be glad you started today.

One brick layer is building a wall, the other a cathedral.

One janitor is sweeping a floor, the other putting a man on the moon.

How do you see your job as an ethics and compliance professional?