Acknowledging the resistance

When ethics & compliance professionals create a new policy, training, or control, it is for the good of the organization. However, it is also likely to negatively affect a small group within the same organization. In fact, it usually does.

This presents us with a choice: we can ignore this small group or we can embrace them. We can consult them early in the process, explain why we are taking this course of action, and ask for feedback and for ideas to minimize the impact on them.

The time we invest up front will generate immense returns down the road.

Disrupting ethics and compliance

We all know what Airbnb, Uber, Zappos and others did to disrupt their industries: they attacked the worst part of the customer experience.

If ethics & compliance was an industry, and employees were the customers, what part of the customer experience should we disrupt? Here are a few ideas:

  • Long policies written in legalese that no one wants to read or can easily understand
  • Risk-based training that doesn’t help anyone to do their day-to-day tasks.
  • A lack of transparency during and after investigations
  • Double standards when imposing discipline
  • Tolerance of retaliation

This list overwhelming and yet not comprehensive. Now is the time for this young profession to realize it is heading in the wrong direction. Changing course is easier to do today than it will be tomorrow.

And it will be less disruptive.

The ability to abstain

It’s been said that addiction is when we’ve lost our ability to abstain.

To abstain from alcohol, cigarettes, coffee, drugs, food, and sex – of course.

But also from the internet, our phone, sports on TV, Netflix and video games.

And, at work, from being negative, complaining, gossiping, and losing our temper. If we do any of these things at work, we are setting the wrong example. If we tolerate any of these things in others, we are not leading.

Daily questions

Here are two sets of questions to increase your sense of purpose and to improve your culture at work:

Purpose

  • How can I help my boss?
  • How can I help my team?
  • How can I help my department?
  • How can I help my company?
  • How can I help my company’s stakeholders?

Culture

  • Can I do this? If yes,
  • Should I do this? If yes,
  • How can I best do this?

On justice

This post was originally published on January 17, 2017.

A century before Martin Luther King’s “Where do we go from here?” speech of August 1967, Theodore Parker said the following:

I do not pretend to understand the moral universe; the arc is a long one, my eye reaches but little ways; I cannot calculate the curve and complete the figure by the experience of sight; I can divine it by conscience. And from what I see I am sure it bends towards justice.

The arc doesn’t bend on its own. The bend is created by the courageous and persistent work of a minority, who possesses a moral imagination capable of seeing a future world that is better than today’s.

And so do we all have a responsibility to see the injustice about us, and to work towards its elimination, even if we never enjoy the fruits of our labor.

You are not obliged to complete the work, but neither are you free to evade it. — Rabbi Tarfon

Caring about what you do

Every month I get a list of new employees from HR.

I use the list to send everyone a welcome email and to invite them to a 15-minute, in-person meeting with me. My goal is to get to know them and introduce our company’s ethics & compliance program.

Not everyone takes me up on the offer but those who do invariably mention how remarkable it was for them to receive this personal gift of time (and I get a lot out of it myself). I truly believe that these 15-minute meetings significantly increase the odds of my new colleagues reaching out for help the next time they struggle with an ethical dilemma. Many have done so in the last few years.

It does make me wonder about those who decide to pass on the invitation. Are they too busy? Are they uncomfortable at the thought of meeting with the ethics guy? Do they think I do this just for show and that we actually don’t care about compliance?

Who knows? Perhaps it’s just that I care more about the topic than they do.

After all, it’s my chosen profession, not theirs.

Primed to Perform – The perfect book to start your culture journey

The best way to reduce ethics & compliance risks is for the organization to have a robust E&C program and a strong ethical culture.

While we need to start with a robust program, an ethical culture is the force multiplier. It’s also the more difficult one to implement. Most leaders don’t know how to define culture, how to measure it, let alone how to change it.

Which is why many organizations today seem stuck. Their compliance program has gone as far as it can go and yet, misconduct is higher than it should be. If this sounds familiar, you may be ready to work on your culture. Of course you’ll need help and there won’t be a shortage of consultants offering it.

Before you hire someone, it might be prudent for you to understand why people work because that’s what determines how well they work (and how ethical they will be). The best learning resource I’ve come across is the book Primed to Perform by Neel Doshi and Lindsay McGregor. It’s an eye-opening book that will change how you think about work and set you down the right path for an amazing culture.

To learn more about Primed to Perform, click on the appropriate tag on this page. My early posts summarize each chapter of the book.

Money talks

It’s happening.

Investors are starting to care about corporate culture. The world’s third-largest asset manager is calling on boards to review their companies’ cultures and explain its alignment with their strategy,

It’s too bad that it took so long. For decades, boards and executives didn’t budge when employees, customers, suppliers and communities begged them to care about culture.

Oh well. It might have been more noble for them to do the right thing earlier, but what matters now is that change is more likely to happen.

Monitoring risk

“Do not eat of the apple” said God. And the first thing they did was taste the apple.

“Do not use text messaging for work”, says the policy. Everyone does it.

At least God was monitoring the garden. As soon as a bite of the apple was taken, He knew.

When it comes to communication channels, organizations often choose not to monitor prohibited channels. And this choice is starting to be costly for some, judging by the size of recent penalties imposed by regulators.

At a time when technology is advancing more rapidly than we can deal with it, simply prohibiting its use is foolish. A better way to respond in the short term is to insist that employees use the technology in a manner consistent with the organization’s values, and to monitor their behavior. With time and experience, sensible rules will emerge.

If a practice appears risky enough to prohibit it, then make sure you monitor it.