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.

From awkward to organic

“I don’t really know how to talk about business ethics to my team.”

This is a phrase that many ethics and compliance professionals have heard from front-line supervisors.

They are afraid of sounding preachy. Or of not knowing the answers. Or looking soft.

If you are one of these supervisors, here’s an easy way to start:

  • Look for a recent ethical breach or scandal reported in the news.
  • Gather your team and ask:
    • Could this happen here? (hint: the answer is usually yes)
    • If so, what would it look like (in this industry, this company, this department, this team)?
    • How could we prevent it from happening?
    • If we could not prevent it, how would we respond to it?

It’s a safe conversation because it didn’t happen to you (yet). Right now, it’s someone else’s problem. But it’s a real problem, not some hypothetical in an online course. And you are not pretending to know the answer – you are asking your team for their ideas on how to protect the company.

Do this on a regular basis, until it becomes comfortable and expected.

Then, like magic, you won’t need to initiate these conversations. Your team will bring them up on their own.

What voice is loudest?

It should have been a straightforward decision.

When the emergency brake on the cable car kept engaging for no good reason, the operator should have closed and fixed the funicular.

Instead, a technician decided to deactivate the emergency brake. The funicular had just reopened after several months of closure because of COVID. There were hundreds of tourists hoping to enjoy the ride up from Lake Maggiore. There was money to be made.

The cable snapped and, without its emergency brake, the car reeled backwards before crashing to the ground and killing 14 people.

We don’t yet know all the facts. But we know that the technician considered the pros and cons of his decision before making it. His mental chatter took into account the tourists wanting to ride, the operator needing revenue, the fact that everyone was looking to him to put the car back into service.

As he heard all these voices, did he also hear the voice of the operator saying that safety was paramount? A voice saying that a few thousands euros wasn’t worth a single loss of life, or even minor injuries, or simply the risk thereof? If he didn’t hear those voices, then why? Was it because this message was never conveyed to him? Or was it conveyed but unconvincingly? Or was the message contradicted by so many others clamoring for efficiency and profit?

What is the loudest voice in your employees’ heads?

Is it one of safety and ethics?

Being a helper

In the early days of the pandemic, a medical student working for a health literacy program noticed that many of her clients didn’t have access to easy-to-understand COVID information because they didn’t speak English.

So she reached out to fellow multilingual students and created 19 COVID fact sheets in 40 languages. These fact sheets have now been downloaded 250,000 times in more than 150 countries. Not bad for a working medical student, who surely has less free time than most of us.

When I read stories such as these, I wonder what else we could accomplish if we simply took ownership. There are so many needs in this world, if we only pay attention. A quick glance at our local newspaper could identify such a need. We could then find others willing to help. There are helpers everywhere.

Let’s be one of them.

What is compliance training for?

90% of your employees completed your online training.

80% of them thought the concepts were clear.

70% thought its length was just right.

60% understood the link to your corporate values.

50% said they learned something new.

40% agreed that it was related to their job.

30% would recommend it to a colleague.

20% thought it would help them be more compliant in the future.


Of the above, what metric do you track?

Of those, which ones do you share with your board?


If 90% of our employees do the training but only 20% think it is helpful, are we doing our job?