What’s your story?

As an ethics & compliance professional, what if your day was live-streamed for all employees to see?

What if they could see you writing multiple drafts of a new conflict of interest policy, and see you push for its adoption, and see you upload it to the website?

What if they could observe the countless hours that go into creating a training module to educate the workforce on preventing corruption – writing the script, selecting the actors, verifying the translations?

What if they could listen in during your meetings with the internal audit department as you scope audits to insure that antitrust controls are effective?

What if they could see the long hours you spend reviewing thousands of emails as you try to gather facts following an anonymous complaint?

What if they could hear the debates of the disciplinary committee to ensure that everyone is treated fairly and consistently?

In that hypothetical world, assuming employee confidentiality and privacy could be protected, I believe that the corporate culture would improve. This level of transparency would foster trust.

In our real world, we can adopt a lighter version of this. We can tell our story – everyone loves a story. We can make employees feel part of that story, because they are part of that story. Storytelling is how people learn best.

Why don’t you tell your story?

#ThinkE&C

During the last week of December, Farida Alkaff challenged E&C professionals to be more visible on social media.

I liked the challenge because I believe in the adjacent possible. I get my best ideas by connecting someone else’s insight to something I already know. The more other E&C professional share their insights, the better it is for everyone.

My answer to Farida’s challenge was to try to write every business day for the first 2 weeks of January. I succeeded and, to my surprise, never stopped.

I would like to renew the challenge and invite all E&C professionals to publish at least one thought every day. Perhaps the easiest way to do this is on the microblogging platform Twitter. You can only use 140 characters. Any thought on ethics or compliance will do.

Will you join in? If so, use this hashtag: #ThinkEandC

Kneel to rise

We might be in business for our customers but I believe we need to care more about our employees than we do about any other stakeholder.

I doesn’t have to be a lot more. Just a bit will do. But employees need to come first.

Airlines tell us to put on our oxygen mask before helping others. Philosophers tell us we need to love ourselves before we can truly love others. Similarly, organizations need to put their employees first if they truly want to succeed.

Costco’s, Southwest Airlines and Whole Foods are good examples of organizations who rose to the top by putting their employees first.

Most of us can’t influence the entire population at our company, but each of us can decide to put our direct reports first. Leaders who do this develop teams that shine among others. Eventually, they attract the best talent and accomplish great things.

Perhaps your organization is not ready to rise to the top of its industry. But in the meantime, you and your team can rise within the organization, and love what you do.

Maintenance is cheaper than repairs

The best E&C programs kick the tires on a regular basis.

They understand that a program cannot run forever without adjustments, maintenance and repairs.

In a large organization, a program will have several elements: antitrust, anti-corruption, government contracting, international trade, privacy, cyber-security, ethical culture, etc. At any given time, one element is in the hot seat, getting all the attention, while another is considered safe and ignored.

A good program will make sure that no element is ignored for too long. Every fews years at the most, we need to kick the tires. If it can’t be done in-house, competent consultants can do this work quickly and at a reasonable price. It’s easy to budget for.

Regular maintenance is often cheaper than repairs.

We get paid $8 for lunch

“Don’t cheat, don’t lie, don’t steal.”

A convenient phrase to (over)simplify an ethics program.

I often tell the employees I serve that if anyone asks them to do something that feels like cheating, lying or stealing, it’s a red flag and they should pause. Whatever they have been asked to do is likely to compromise our values of trust and integrity.

We would like to think that the obvious does not need to be stated. But what seems obvious on a blog post or in a classroom setting is not so obvious when we add the emotional and financial pressures of the workplace.

In my late teens, I worked as a helper on delivery trucks for a large corporation. It was a union job and our contract allowed us to be reimbursed for lunch. Each morning, the truck drivers/salesmen would agree on where to meet for lunch. On my first day on the job, the waitress gave everyone at the table a receipt and I completed mine. One of the drivers, a 30-year veteran, saw that I had written $5.50 on my receipt, took it, and asked the waitress to give me a new receipt. He told me “We get paid $8 for lunch. Write $8 on your receipt.” Everyone else at the table chuckled, and I complied.

Of course, we didn’t get paid $8 for lunch. We got reimbursed up to $8. I was young. I wanted to fit in. I needed the job. And so I didn’t pay attention to that feeling that I was cheating, lying and stealing. Because of the pressures at play, within seconds I rationalized my behavior and thought “Well, the union negotiated for $8, so it must be OK.”

Perhaps things would have been different if the company had an ethics program, if it had a confidential hotline, if it communicated its values and the importance of accurate books and records, or being a good steward of the shareholders’ money.

It’s hard to tell, 30 years later. The world has changed.

But I do remember the pressures that I felt at that moment. And those pressures haven’t changed much today.

Scaling trust

In a large organization, it is often difficult, and sometimes impossible, to adopt a new idea that will work for everyone.

So instead of accepting this reality and allowing good ideas to find a smaller home, we reject them entirely.

If it doesn’t scale, we don’t want it.

But what if we could scale the unscalable? What if we allowed good ideas to take root in tiny corners of our organization?

Chaos, you think? Unmanageable? Risky?

Perhaps.

Or perhaps there is a trust issue at play.

A new definition of compliance professional

These are my reading notes and thoughts on the book titled Influence by Robert Cialdini.

Introduction

I did not expect the first paragraph of this book to stop me in my tracks but it did. After admitting that he is an easy prey for people selling magazine subscriptions and raising money for charities, the author writes this about compliance:

Probably this long-standing status as sucker accounts for my interest in the study of compliance: Just what are the factors that cause one person to say yes to another person?

In my 13 years in the E&C sphere, I had never thought of compliance as a process leading others to say yes to me. Compliance had always been about the question “Can I?”, while ethics was about the question “Should I?”. Compliance was about the law, about the rules. I had always looked at compliance from the perspective of the one being ruled – the employees ruled by the company, itself ruled by the regulators. Cialdini, it seems, is approaching compliance from the perspective of the ruler.

This mindshift comes on the heels of another concept I heard for the first time recently: most compliance failures do not result from a lack of awareness or understanding but from others not believing what we – the compliance officers – believe.

Put together, these two notions suggest that a successful compliance officer is one who, using the influence principles, communicates her beliefs in such a way that causes others to say yes the compliance program.

Imagine organizations where E&C professionals possess such skills.

This approach to E&C is interesting, to say the least.

Why not you?

Perhaps you can’t change the culture of your multinational.

Perhaps you can’t change the culture of your country operation.

Perhaps you can’t change the culture of your local business unit.

Perhaps you can’t change the culture of your branch.

Perhaps you can’t change the culture of your department.

Perhaps.

(And perhaps you are wrong)

But you can change the culture of your team, of that unit that you lead. This is your tribe. People like you do things a certain way. You can be an oasis. A shining example of what’s possible. Others have done it. And have changed the world.

Why not you?

Policy communication: the bite-size approach

A typical policy deployment looks like this: the new policy is added to the manual, it is featured in an article on the intranet, the leader talks about it during a town hall and then… it fizzles.

A typical question from E&C professionals is: how can we create a longer-lasting effect?

One idea is to chop the content of the policy into, say, twelve small bits and use one every month for a year-long communication campaign.

With little effort, we go from one big, loud launch to a sustained effort to educate and send the message that this new policy is important and here to stay.

Take for example a new policy on the FCPA. At a minimum, it will define what a payment is, who are government officials, what a corrupt motive is, what an improper benefit is, and what it means to obtain or retain business. It is not difficult to identify five short articles covering those elements. Each article can follow a simple format:

Open with a reminder of the policy: “In this 2nd installment of a series covering our new FCPA policy (available here), we will explain the concept of “foreign government official…”
Cut-and-paste the relevant text of our policy
Link this text to what actually happens in our business: “Here are examples of foreign government officials that we deal with on a regular basis…”
Tell them where to go if they need help: “If you are not sure that you are dealing with a foreign government official, call your legal department…”
Announce the next installment: “Come back next month when we’ll discuss…”

And there you have it. Six months of sustained communications, offering bite-size content that everyone can fit in their day.

Do you have other tips on effective policy deployment? Please share them in the comment section below!

Everyone is a media company

“Everyone is a media company” – Gary Vaynerchuk

Ethics & compliance professionals are:

A media company/compliance counsels
A media company/ethics officers
A media company/policy makers
A media company/investigators
A media company/auditors
A media company/trainers.

If we don’t

Have a blog at work
Present at employee meetings
Interview company leaders on a podcast
Publish short videos on the company’s intranet
Or otherwise document and share the work that we do,

Then we don’t exist.