An ethical culture ensues

We know that happiness ensues, that it is not something that we can pursue directly.

We know that success ensues, that it is not something that we can pursue directly.

Yet, most of us go about it in all the wrong ways. And so rare are those who are happy and successful.

The same is true of corporate culture.

We know that it ensues from caring more about our employees than we do about our customers, suppliers, and shareholders.

Yet…

Is it really safe?

You can ask employees to speak up but they probably won’t.

You can tell them that they will be protected from retaliation but they might not believe you.

You can write all of this down in a policy but it’s not likely to make a difference.

You can provide training about the importance of raising concerns but that doesn’t make anybody feel safe.

It’s all talk.

What we need is action.

We need leaders who keep their door open.

We need organizations that support ombudsman programs.

We need managers who follow up with those who raise concerns to let them know what they’re doing about it.

We need employees who are recognized for speaking up.

We need to hear about the ones who get fired for retaliating.

The desire to fit in, to belong, is deeply ingrained in human beings. Few will risk the safety of their tribe by outing another member.

Not until they feel safe in doing so.

Say what?

Today, many organizations have employees in more than one country and speaking more than one language. When we operate in jurisdictions with multiple official languages, our E&C program – at least the mandatory part of it – ought to be available in all languages, even when the local law does not mandate it.

Yes it is more work. Yes it is burdensome. Yes it is expensive.

But it’s a sign of respect for our employees.

When good people do bad things

Too often, we see colleagues lose their job for covering up a mistake that would not have led to any form of discipline, let alone their termination.

Those are the saddest moments.

They expose a low-trust culture where an employee is willing to risk her job or her career for fear of admitting a mistake.

Our typical response – to shake our heads in disbelief and then move on – is unacceptable. Someone just lost their job, in part because of the culture we created or tolerated. We ought to examine how we do things and look for what might have led to this unfortunate outcome.

Questions to ponder:

  • How do we react when others make mistakes, miss a deadline, fall short of a goal? Is the reaction commensurate to the missed opportunity?
  • When we make mistakes, do we admit them freely? Do we share the mistake and its learnings with others (demonstrating that one can survive mistakes)?
  • Do we go as far as encouraging mistakes by asking our employees to be curious and to experiment?
  • Do we recognize colleagues for pursuing innovative ideas, even if they fail?
  • Do we have unforgiving compensation schemes, where huge bonuses are paid for meeting 100% of the goal but nothing if 99.9% of the goal is met?
  • Do we offer an ombudsman program where employees can ask for advice while remaining anonymous?
  • Do we forgive mistakes made by senior leaders more easily than those made by the rank-in-file?

To be clear, employees who cheat, lie, and steal to cover up a mistake deserve to be punished. But let’s remember that everyone has a breaking point. So when someone breaks, how much of that pressure came from us?

What we get when we don’t ask how

If you work for a large organization, here is a scenario you might face:

  • A sales employee in a small branch of a developing country deals with a reseller that does not have the resources to issue a purchase order for its daily orders.
  • Your sales employee, trying to be helpful, creates the purchase orders on behalf of the reseller using a blank stack provided by the reseller.

Scenarios like this happen when we do not explain the importance of accurate books and records, of segregation of duties, of financial controls.

They are also a symptom of what happens when employees believe that we would rather have them circumvent controls (and get the sale) than raise the issue (and delay/lose the sale). This belief typically arises when we repeatedly communicate our financial goals and never ask how they will be / have been achieved.

The ethical leader understand that how we do things is just as important as what we do.

Scorecards and emotional pressure

On the one hand, dashboards and scorecards are extremely useful. In one glance, we know where we stand. We can see what is working and what is not. Where resources are adequate and where they are not. The information highlights the action that must be taken next.

On the other hand, these tools can apply a crippling amount of emotional pressure. No one wants to be at the bottom of the scorecard or see their numbers painted in red on the dashboard. And before you tell me that this can be a great motivator, have a look at the latest science on this topic. The bottom line is this: in today’s workplace, emotional pressure hurts performance.

So, should dashboards and scorecards be eliminated? Of course not. What this means is that these tools are most effective when trust is high and when all individual players care more about the team than they do about themselves. For that to happen, they must feel safe. They must know that showing vulnerability will summon support, not predators.

Do you feel safe?

Hunt the good

Ethics and compliance professionals often operate in a negative environment. Most of our work is in reaction to wrongdoing.

This reality can negatively affect how we perceive the world and how the world perceives us. In fact, it can negatively affect how we see ourselves.

A countermeasure is to hunt the good and put our catches in trophy cases. Here are some ideas:

  • Policies can refer to our organizational values and demonstrate how their application will have a positive impact on the organization.
  • Training can be at the task level (not the risk level) and focus on how it will help employees do their job.
  • Controls can be presented as tools to protect employees from negative outcomes.
  • Audits can highlight best practices (not just deficiencies).
  • Investigations can be conducted by people who assume a positive intent.

Makes sense?

If you have found ways to shine a positive light on an otherwise negative environment, please share by leaving a reply below. Thank you.


Hat tip to GaryVee, JC Glick, The Broadcat and Vega Factor

Retaliation = Termination

Retaliation should be considered public enemy #1 of any ethics & compliance program.

An organization’s health depends on employees speaking up when they have a question or a concern. This is how we identify and address risks, and how we prevent and detect wrongdoing. Retaliation silences those who should protect the company.

Termination of anyone engaging in retaliatory behavior is almost always the right outcome.

Your Tweet matters

Today is the last day of our ThinkCompliance17 challenge. The idea was to increase the number of voices discussing matters of compliance on Twitter.

Did we succeed?

Using the search bar on Twitter, I counted a total of 204 Tweets with our hashtag, or about 15 Tweets/day. When you quickly swipe up the search results, you notice that most of these Tweets were posted by a handful of users, many of which were already active on the Twittersphere. And the majority were reTweets, not links to original content.

Most people, including me, are afraid to write publicly (and no, putting a picture of your cat on FaceBook does not count as writing publicly). Writing about ethics and compliance can be even more daunting. I get it.

But let’s face it: the state of business ethics could be better. We know this because we all work for someone else or are regulated by a government. For the most part, employers and governments react to pressures. No pressure, no action.

A boss who never talks about ethics and compliance sends the message that it is not important to her. Employees send the same message to their employer.

All that is required is to pay attention, notice how things are, and write about it. Even a 140-character Tweet counts (if it’s not just a link to someone else’s thinking). It’s up to all of us to start the conversation.

Are we up for the challenge?