Are you getting what you pay for?

How much do you spend on online courses to educate your employees about ethics and compliance?

It’s not just the amount you pay to the course provider (internal or external), but also the time spent by the E&C personnel to administer the training platform, and the salaries of your employees while they take the training. In large corporations, the last item can be in the millions of dollars.

At the end of every course, employees should be asked “Will you be able to perform your work more compliantly as a result of taking this course?”

Compare the survey results to the amounts your are paying, and ask yourself if it’s worth it.


P.S.: Most companies don’t want to know.

On feeling heard

As many of us work from home, some companies worry about employee performance. Employers are asking “How can I keep my team engaged?”

According to a Salesforce Research report, one of the most powerful things a manager can do is to make sure her employees feel like their voice is being heard. Employees who feel their voice is being heard are 4.6X more likely to feel empowered to perform their best work.

So now more than ever, managers should solicit feedback from employees. Ask them how you are doing as a manager, what you could do better, what worries them, and what they need to do their job. And know that you don’t always need to have an answer for everything. Sometimes, psychological air is all that is needed. And if you want helpful feedback from them, make sure you are transparent about the current situation and your future plans.


Speaking of feedback, this blog is approaching its 700-post milestone. How am I doing? What could I do better? What would help you better navigate ethics & compliance issues at work? Please let me know in the comment section below. Thank you!

When angry, pause

How much more harmful are the consequences of anger and grief than the circumstances that aroused them in us!

Marcus Aurelius, Meditations, 11.18.8

A child spills milk and a parent barks a nasty comment that will resonate for years.

An employee generously offers constructive feedback to a boss, who then chooses to retaliate.

A citizen is suspected of using counterfeit money to buy cigarettes and is killed by the arresting officer.

What we need is to exercise our ability to pause. Here is how Dov Seidman puts it: “One of the simplest and most powerful tools we have as individuals is the ability to pause. Think about it. When you press pause on a machine, it stops. When we pause as humans, we begin. Pausing creates a space where one can see clearly, differentiate amongst the competing stimuli of daily life, and make determinations about how to best move forward.”

And the best way forward is not to create harm but to create a better world (tikkun olam). Today and every day, let’s recognize what ignites anger in us, let us pause, and let us begin to repair the world.

Questions that can save lives

According to documents released by Boeing, one of its employees said in an email that the 737 Max was “designed by clowns who in turn are supervised by monkeys.” Another one said he would not let his family fly on the aircraft.

Are your employees having similar conversations about your products and services? Are you actively trying to learn about these conversations? Are employees encouraged to speak up? Do you have a confidential reporting channel?

And if employees do share their concerns with their managers, do the managers know how to listen? Do they know how to escalate the concerns? Do they know how to follow up? Do they know to provide regular feedback to the employees?

Answering these questions can save time. It can save money. And, in rare occasions, it can also save lives.

Wrongdoing is where the pressure is

Before the Wells Fargo scandal broke out, the company fired 5,000 employees engaged in opening fake accounts.

Imagine if after the first 100 terminations the CEO had held skip-level meetings and asked “You know my ‘Eight is Great!’ slogan? Is that making your job impossible?”

From time-to-time, every organization has its version of “Eight is Great!”. It can be a revenue goal, market share, organic growth, or some government approval. Whatever the initiative, leadership needs to include in it a process by which employees can provide feedback on its effects.

Where is the pressure in your company today?

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.

On the importance of sharing survey results

A few times each week, I receive a customer satisfaction survey from a company I deal with. It can be from my car dealership about my oil change, from my dentist about my kid’s last visit, or from the phone company after I called to question a charge on my bill.

I rarely respond to the surveys. In part, it’s because I prefer to spend my time doing other things that are more important to me. But more importantly, it’s because I never hear about the results of these surveys. Neither my dealership, nor my dentist, nor my phone company sends me a report showing how satisfied their customers truly are and how they intend to change based on the feedback I and others have provided. In other words, I get very little, if anything, out of the process.

This is why I find it critical for leaders to share the findings of any employee survey conducted at work. Not just the big annual or biennial employee survey but any survey, including the one we send after a short training session. It shows respect for those who took the time to answer it. It demonstrates leadership’s willingness to be transparent and vulnerable. It evidences the effort that leadership put into reviewing the answers and coming up with action plans. And it creates accountability for the execution of said plans.

It’s a great way of saying “Thank you for caring.”

On investigations

One of the best ways to show your employees that we care about them is to take action when they report improper behavior.

When thing go badly in the workplace, a robust investigative process and timely feedback can make a huge difference for the reporter.

No matter how long an employee works for us, they will vividly remember the time they reported wrongdoing and the ensuing investigation. It will stand as one of the most emotional moments of their career. Their courage to speak up should be rewarded with a thorough investigation and protection from retaliation.

Embedded communications

Yesterday I was forced to host a call to bring colleagues up-to-date on a key project. Over the last weeks and months, I had not met the information needs of all stakeholders. As a group, we spent about 8 person-hours on this call. It would have taken me far less time to send them a brief email update each week.

We often neglect communications because we would rather do than talk about what has been or will be done. We have so little time to accomplish what’s on our plate, it seems logical to spend every minute doing the work.

What we fail to recognize is that the importance of communication is embedded within each project. If it’s important enough to be done, it’s important enough to be talked about, to be shared, for feedback to be sought, for accounts to be rendered.

As we determine how much we can have on our plates, and as we prioritize our work, we need to include a communication element to every project. Yes, this means that some projects won’t make the cut, at least not right away. But the projects we do work on will meet a greater degree of success. And the people we work with will perform better.

Drip-drip-drip vs. big-boom

My organization will be launching a revised Code of Ethics later this year.

We are creating a communications campaign to support the launch. Employees will want to know what’s new with the Code, why we revised it and how this new document is supposed to help them to their job.

Rather than creating a traditional launch campaign that is short and loud – to get attention, we are creating one that will be softer and sustained – to be absorbed.

For example, we are working on a series of short emails that will contain a “hook” to make employees click on a link to learn more. One of them will contain a picture of a gift on a desk and read something like “You arrive at your desk and see a beautifully-wrapped gift with a card that bears the logo of a supplier. Want to know what’s inside? Click here!” This will bring them to a webpage where we tell the story of a real case, explain what gifts employees are allowed to accept, why we have a gift policy and, obviously, a link to the relevant conflict-of-interests section in the new Code.

A drip-drip-drip approach will keep the conversation going for several months and will allow us to adjust our communications as we receive feedback. It’s not as intense as the big-boom approach but we expect a deeper effect.