On sharing

Today, share something you know about ethics and compliance with a colleague, face-to-face.

Or share it via email with another E&C professional.

Or present at the staff meeting of a small department.

Or ask for 10 minutes at your company’s all-hands meeting.

Or organize an informal meeting of E&C professionals from your city or county or state. Host it in your office.

Or accept an invitation to present at another company’s event or at a professional association meeting.

Or write a guest blog post. Or start your own blog.

Or be a guest on a podcast. Or start your own podcast.

Or start a vlog.

But don’t keep what you know to yourself.

There is someone out there looking for the answer that you have.

On emergencies

Some people who end up in the emergency room created the emergency.

After months or years of eating poorly, being sedentary and sleeping too little, they are rushed to the hospital. Death, disability or a massive life change will be forced on them.

The same can be said of organizations who implode from a news scandal. After months or years of neglecting healthy habits of ethics and compliance, their survival is at stake.

If your organization was rushed to the emergency room tomorrow, would it be for a cause that was preventable?

If so, you have your marching orders for the day.

On experiments

As E&C professionals, we routinely notice flaws in our policies, training, controls, audits and investigations.

The solution we identify is sometimes uncertain and often outside of our budget. We need to make a case to our business leaders but all we have to offer is a certain extraordinary expense and an uncertain outcome. We can’t blame them for being reluctant.

There is a slower but more convincing way to go about it. We can conduct a small experiment in a discrete part of the business to test our idea. If we see the promised improvements, we can then extrapolate the savings to the entire business and make a stronger case to our leaders.

It may be discouraging to think that we will need a year or more to accomplish something great. But it’s better than proposing 10 untested ideas that go nowhere.

On performance incentives

You cannot incentivize performance. You can only incentivize behavior.

– Simon Sinek

We cannot incentivize sales. Sales can’t do anything.

Sales result from the effort of sales people interacting with customers.

What we need to incentivize is the salesperson’s desire to learn about the offering – what it does, its value, who it’s for – and to learn the skills required to connect her offering to the customer who needs it.

Many companies simply offer a bonus to anyone who meets a sales goal. Year after year, the goal gets higher. The employee’s performance is supposed to improve without the learning of any additional skills. Of course, that’s not possible. Eventually, the salesperson will be unable to meet the goal without cheating or lying. Without realizing it, the company has incentivized maladaptive performance.

The next time you set an incentive, consider all the behaviors you will affect.

Thoughts from the ECI Best Practices Forum

I spent the last two days in Dallas for the Ethics & Compliance Initiative (ECI) Fall Best Practices Forum. The topic was “Building a Respectful Workplace.”

I walked away with many concepts and ideas to explore. Here are a few:

  • Employees used to protest (strike) only for better wages and benefits. Now, they take to the streets to decry what their employers tolerate in the workplace (e.g. Google, McDonald’s, etc.). How much internal dialog took place before this boiled over? Did the companies listen? Did the companies feel they could just ignore the complaints? How should companies change to address these concerns before they spill into the public realm?
  • When asked what type of misconduct they observed in the last 12 months, employees consistently place abusive behavior in the top 3 list. So why don’t we ever see this risk on an ERM mitigation plan?
  • The more powerful the perpetrator of wrongdoing, the more likely s/he is to retaliate against the person reporting the behavior. Do we have a process in place to monitor retaliation by executives?
  • Incivility in the workplace increases misconduct. Diversity in the workplace increases civility. Can we thus argue that diversity reduces misconduct?
  • When you strongly disagree with someone, adopt a position of curiosity.
  • Our fear of conflict leads us to agree with the majority. What can we do to make people feel safe in holding a different opinion? What is the point of diversity if no one is willing to speak up?
  • Take this test to find out your implicit associations about race, gender, sexual orientation, and other topics: https://implicit.harvard.edu/implicit/
  • The science shows that the psychopath “top performers” are actually not helping the organization reach its performance goals.
  • Every company has some leverage over a segment of society. Why not use it for good?
  • “A solution should not cost more than the problem.” Is this a valid argument only when you put your shareholders at the top of the list?
  • When having a difficult conversation, separate the people from the problem. Be soft on the people and hard on the problem.
  • When asking questions, decide if they are in service of the other or of you.

On voting

Last night, I voted to get up at 6 AM this morning.

This morning, I voted to eat an English muffin for breakfast.

We vote all the time. Every decision is a vote.  Most of what happens to us doesn’t matter but every decision we make is of significance.

Yet, we make countless decisions without thinking and constantly complain about what happens to us. We don’t realize that one is a consequence of the other.

Tomorrow, make your vote count.

What if your pilot had no checklist for take-off?

Some things are complex. Flying an airplane, building a house, or performing surgery are no simple matters. Making an error while engaged in these activities can have disastrous effects. This is why the pilot, builder and surgeon all have a checklist and a process to follow. They have a system to ensure that no mistakes are made.

Creating the right culture in our organization is no simple matter either. Yet, many of us have no system in place to guide us through the complexity. We leave it to chance – to the tens or hundreds or thousands of supervisors to behave in the perfectly coordinated way that will lead to an ethical culture of compliance. We act as if each will magically know how to hire, onboard, compensate, promote and discipline their employees.

When surgeons were first required to write their name on the limb they were about to operate on (while the patient is still awake), their egos were affected. But the practice was soon praised by all for eliminating mistakes.

Perhaps it’s time for corporate executives to create systems leading to a better culture.

Even at the risk of bruising some egos early in the process.

Hat tip to The Checklist Manifesto and Seth Godin

Vulnerability: an essential ingredient of a speak-up culture

I had the opportunity to present my company’s ethics and compliance program to another company yesterday.

Some of my remarks touched on the importance of creating a speak-up culture. One attendee asked me what I thought was the best way for managers to encourage employees to speak up.

My answer was to show vulnerability. When employees speak-up, they feel vulnerable. Nothing will encourage them more than seeing their own supervisor be vulnerable. If you are a supervisor, pay attention to your small moments of courage and find a way to share them with your team. If you do it consistently, your employees will learn to trust you and to demonstrate the same courage.