“You shouldn’t do indirectly what you wouldn’t do directly.”

We often think of this rule when hiring sales agents. Sales agents should not be used to do things that our own sales force could not do, like paying bribes.

There is a corollary to this rule. It might sound like this: “If you should do it directly, make sure you also do it indirectly.”

Say that you always do a background check on your hires. If you decide to use a labor provider, then you should insist that their background checks are as rigorous as your own.

Behavioral science found that humans can better tolerate wrongdoing when they are not the ones engaged in it. So the vigilant E&C professional will always scrutinize relationships between her organization and its partners.

If you work in ethics & compliance, you spend most of your time preventing or reacting to wrongdoing.

This can take a toll on your life, mood and outlook.

So take time each week to reach out to those who benefit from your work. Accept their praise and thanks, in all humility. Let these positive connections energize you.

Hurricane season is back in the United States and several southern States are now bracing themselves against hurricane Dorian.

The vast majority of people will prepare adequately by barricading their windows, by stocking food and water, and by evacuating when the order is given. But a few won’t. They’ll try to ride the storm and, as it happens every time, they will need to be rescued. Some won’t make it out alive.

There are similar storms in the ethics and compliance world. FCPA, GDPR, #MeToo, cybersecurity, opiods, etc. We see them coming and can choose to prepare for them or not. Each time, a few companies or leaders are shaken. A few never recover.

What storm is looming over your company today?

The belief that a corporation’s paramount duty is owed to shareholders has been the greatest obstacle to business ethics in the last 50 years.

That belief appears to be changing, at least for the CEOs of Johnson & Johnson, JPMorgan Chase, IBM, and the other 200 or so American CEOs that are members of the Business Roundtable (BRT).

The BRT is finally recognizing the equal importance of employees, suppliers, the communities where we work, and of the environment in general. Going forward, when shareholder monies will have to be spent on protective equipment for employees, we won’t have to demonstrate that the cost of steel toe boots for 1,000 employees is cheaper that the cost of a hospital visit for the occasional injury. We will be able to say, simply, that we want our employees to be safe at work. Similarly, when we give our employees the day off to clean the banks of a local river, it will be because we want to give back to our host city and not because we seek some productivity gain from “happy” employees.

The BRT CEOs have spoken. They are pointing the rest of the corporate world in a new direction. It’s time we all start marching.

It’s not easy to change how we hire, compensate, promote, discipline and fire people.

Especially when we try to change quickly in an effort to improve the culture.

It’s much easier to create a new habit around a tiny part of each process and to stick to that habit. We can decide to meet with each new employee for 10 minutes and let them know that we are there for them when they face their first ethical dilemma. We can ask team members if they know of any reason why a colleague should not be promoted. We can publish weekly stories of employees doing the right thing in an effort to normalize their behavior across the company. So on, so forth.

Create a multitude to non-threatening habits, each one nudging the culture in the right direction, and watch your culture improve – seemingly without resistance.

Trust but verify.

This is the role of many governmental agencies. They provide oversight of industries that promise to make life better – with associated risks.

The US Food and Drug Administration (FDA) is one such agency. Before approving a life-saving drug, it requires pharmaceutical companies to submit data on its effectiveness and safety. Some companies, like Novartis recently, choose to hide relevant data to improve their chances of FDA approval.

I bet that some people at Novartis don’t think that the FDA is on their team. They don’t believe that both organizations are in the business of delivering safe drugs to the public. This is true of other regulated industries, where the regulator is seen as a foe, not a friend. Think of Volkswagen and the EPA.

The same dynamic is often found inside a company. We see it between the sales function and the control functions, or between the business units and the corporate headquarters. One group feels unjustly restricted by the other and tries to evade the controls. Many readers of this blog are in the E&C function and they know what I am talking about.

What is the culture at your organization? Are the control functions considered to be part of the team? If not, this should be your first priority.

Another week, another mass shooting in the US.

Two, actually.

After each incident, the local mayor proposes new ways of reducing gun violence. The state governor usually joins in. And nothing ever gets done. There has been more than 250 mass shootings in the US in 2019 so far.

What if your workplace and colleagues were the target of the next deranged shooter? Would you be ready? Do you have the right policies, training, controls and culture in place to prevent or defeat an attack?

If your organization’s code of ethics promises a safe workplace to its employees (as most codes do), you’ve obligated yourself to be ready. Don’t count on your government, at least not in the US.