Who is it for?

I often sit down to create a document that will be helpful to the ethics and compliance officers (ECOs) that I support. It could be a policy summary, an FAQ, or a quick reference guide.

In the middle of it, I’ll sometimes realize that the information I’m including could also be very helpful to the employee population at-large. So I’ll change the focus and try to write a document for all employees that my ECOs could also use.

I’ve learned that this is usually a mistake. When you try to write for different audiences in one document, the needs of one audience (or both) will be neglected in the process. It might be more work, but writing a separate document for each audience is better.

The first casualty of war

In the last few days, Russia has restricted its citizens’ access to social media and made it illegal to publish news that contradict information provided by the Kremlin.

Truth is the first casualty of war, as they say.

In some organizations, gentler but similar tactics are employed by leadership. Employees are not allowed to use social media at work. When they use it at home, they can never mention their employer on their profile or their posts. Articles published on the company’s intranet have no comment section for employees to chime in. Employees cannot ask questions before, during or after town hall meetings. I could go on.

The message is clear: the company has one voice, and it will not be contradicted.

Is your company at war with its employees?

Good communications

The CDC is being criticized for holding only two briefings in 2021.

That criticism is justified. In a crisis, uncertainty adds fuel to the fire. Frequent, accurate and practical information from the authorities can keep things under control.

At my company, in the early days of the pandemic, I noticed an important change. My leadership not only increased the frequency of its communications but also the quality. They not only increased the amount of technical support (for remote work) but also of emotional support (for all employees). Significantly, that effort hasn’t let up yet.

Whether it’s a pandemic or a new gift policy, a change from what was normal requires good communication.

What change are you about to experience at work in the coming weeks? How well will you communicate it?

Starting fresh

When you get a new phone, you can set it up by copying everything from the old one. Or, you can set it up manually and “start fresh”. The first option is very convenient. The other forces you to consider whether you really need all these apps.

When you do your annual budget, you can tweak last year’s. Or, you can do a zero-base budget and “start fresh”. The first option is less painful. The other forces you to consider every upcoming expense.

When you create your 2022 E&C communication and training plan, you can use this year’s plan and (kinda) change the topics. Or, you can create one based on your latest risks and violations and “start fresh”. The first option offers less friction. The other sends the message to your employees that you (and them) are not engaging in a check-the-box exercise.

Keep it up

Heraclitus said that no man ever steps in the same river twice. Not only does the river constantly change, so does the man.

Similarly, every time we read a book, we see something new. The book may not have changed, but we have.

As such, we should not hesitate to exhort our employees, over and over again, to do the right thing. Between the last time we’ve asked and now, they have changed, and so have we. This time, it will click for some of them.

And for others, it’ll be the next time.

Keep it up.

Getting attention

As things happen to us today, our brain will filter most of it out.

For example, as you read the previous sentence, you didn’t pay attention to the color of the floor, you didn’t notice the background noise, you didn’t smell your coffee, and you weren’t aware of the pressure of your chair on your back.

And as we later recount to someone what happened to us today, we will omit most of it.

“How was your day, honey?” “Oh, great! Sam and I met for lunch and I had the best salad. Then, after work, I went to check out the new gym near the office… leg press machine… then picked up some wine… kids’ homework…”

And whoever listened to our day’s recap will only absorb some of it.

This is just how brains work. They pay attention to what is important to this person at this moment.

It’s helpful to remember this when we attempt to communicate with, or train our employees.

Keep it short. Keep it simple. Make it impactful. Make it useful.

If your employees need to remember something, make them want to remember it. Once they want something, they will pay attention to anyone who offers it to them.

Documenting and FAQs

Ethics and compliance officers often share with me their struggle to communicate about the E&C program. “How many different ways can I tell them about our code of conduct, our policies and our training?”, they ask.

Two ways are often overlooked:

  • Documenting: Let’s say you are in the process of revising an existing policy. Share that with your employees. Tell them you are launching the revision process and why. Later, tell them how you partnered with HR to get feedback on the first draft. Once approved, share the questions that leadership asked before approving the policy. You can do that with any project you are working on. Documenting gives you a chance to stay in front of your employees, to tell a story (that’s how people truly learn), and to add transparency to your work (transparency promotes trust).
  • FAQs: If you don’t have a big project to document, then consider writing FAQs. You can easily write FAQs about your code, about each of your policies, about your training, investigations, controls, etc. All you have to do is collect the questions you get from employees and organize them. Once you have 3 or more on a given topic, you can publish the FAQ.

Of course, you can also document your creation of FAQs!

All eyes on you

A few decades ago you could only learn about organizational culture in academic papers that no one read.

Then professors and writers like Ariely, Covey, Grant and Pink wrote best-selling books that made the academic papers more accessible.

Today you can find daily articles about corporate culture in Forbes magazine and the Wall Street Journal.

With today’s wide availability of messages on the importance of culture, which message is the most important for your employees to hear?

Yours.

Looking back, looking forward

Go to your “Sent” folder and search for 2020 emails containing the word “ethics”.

How many are they? What’s the average per week? Did you send them to your direct reports, your peers or your supervisor? Were you praising a good outcome, raising a concern or simply reminding people to complete their online training?

2020 offered us plenty of opportunities to demonstrate ethical leadership. Did we grab them?

Can we do better in 2021?


Click here to see what your employees are searching for.

Exercise for the coming week

  • Write “Ethical Dilemmas” on a blank sheet of paper and leave it on your desk where you can see it.
  • At the end of each day, write down one ethical dilemma you encountered.
  • Right next to it, write down your decision and why you decided this way.
  • Next, identify how you could share your decision with your entire company, or your team, or at least one person.
  • Then go ahead and share one decision at the end of the week.

Repeat next week.