Today, make a list of all the tasks you accomplish as an ethics & compliance professional.

When the day is done, review your list. At least one task, if not all of them, will have brought value to one or more of the employees you serve.

Share that.

Share that with your E&C colleagues, on your blog, on your organization’s intranet, with a professional organization like the ECI, on Twitter, on LinkedIn.

Anywhere.

But share.

This is a time when we need to see more examples of trust, respect and integrity.

In the workplace and beyond.

Teaching business ethics

Today is an academic day for me. I am presenting at Bentley University in the afternoon and teaching at UConn in the evening.

In many fields of study, the role of the teacher is to impart knowledge on her students. We expect English and math students to learn facts about these topics.

With business ethics, my aim is different. I seek to influence behavior.

I teach to move my students along the ethical leadership spectrum, from ethically unaware (in some situations) to ethical leaders. I teach that culture is an outcome, that it can be measured and improved. I teach about organizational integrity because personal integrity is not enough.

My quizzes and tests cannot measure my success. The real tests will be administered when my students enter the workforce. Will they recognize the ethical dilemma? Will they make the right decision? Will they implement it in a way that inspires others to do the right thing?

I don’t expect for a second that all my students will ace these real-life tests.

I can only hope that some will, some of the times.

And that it’ll make a difference.

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.

Inputs –> Outputs –> Outcomes

In the ethics & compliance world, many professionals struggle to measure the effectiveness of their program.

We pick a few easily measurable metrics, such as the number of allegations made, and are quickly puzzled. What does it mean when that number goes up or down?

The more experienced professionals realize that input metrics are rarely helpful to measure effectiveness. They do offer an opportunity to ask good questions but they seldom provide an answer.

Output metrics are more telling. Let’s say we typically get 100 potential conflict of interest disclosures during our annual survey. This year, for the first time, we hold five lunch-and-learn sessions (input) the week before the survey to explain the different types of conflicts and why it’s important to disclose them. If our disclosures double (output), then we can probably say that our training campaign was effective.

But is this the business we are in? Is our role to generate allegations and disclosures and training completions?

Of course not.

Our role is to drive behaviors that are consistent with our organization’s values. Generally, the outcome we seek is an organization that generates trust, treats everyone with respect, and performs with integrity.

And so an effective program is one that generates the right outcomes. The relevant metrics tend to be more qualitative than quantitative – and thus harder to measure. The good news is that there are competent professionals out there who can measure these outcomes.

It’s the only way to truly measure the effectiveness of our E&C programs.

Hat tip to Todd Zipper

Locks are for honest people

I remember being startled the first time I heard the expression that “locks are for honest people.”

My whole life, especially as a kid, I had assumed that the locks on my house or my parents’ car were there to stop burglars and thieves.

Now I get it.

In the E&C world, we could equally say that internal controls are for compliant people. Those who lie, cheat, and steal will find a way around the controls.

As a kid, my parents, my teachers, and my clergy all taught me the importance of trust, respect, honesty and integrity. So, if I spotted a new shed in the yard of that old couple, and my boyish impulses to discover the treasures inside were frustrated by a lock on the door, I naturally walked away, disappointed. Never in a million years would I have even considered the possibility of trying to defeat that lock.

That is the power of values and culture.

And that is why, when one of our employees defeats a control, we need to do more than increase our controls. We need to ask “What is it about our culture that this employee felt the need to behave this way? Why are our values of honesty and integrity not espoused?”

Locks are for compliant people. And culture is the road to compliance.

If you think integrity is hard, try dishonesty

An organization of “ands” is an organization that requires its employees to make the numbers and to do it safely and to do it ethically. It’s not one or the other.

Contrary to popular belief, working in an organization of “ands” is not more difficult. It’s actually way easier. We don’t have to struggle with compromises. We either do it the right way or we don’t. We never have to figure out how to lie, steal, or cheat without getting caught. If something cannot be done ethically, we move on to the next opportunity.

If you think integrity is hard, try dishonesty for a few years and let’s reconvene then. One of us is going to be in a much easier spot.

Personal integrity is not enough

I am currently in steamy Singapore (90 F and thunderstorms) to participate in training sessions and workshops with 40 ethics & compliance colleagues from my organization.

Yesterday, we discussed the difference between personal and organizational integrity and reputation. In essence, a leader with personal integrity will enjoy a good personal reputation, and that is all fine. But unless that leader is also committed to creating and supporting processes that protect the organization’s integrity and reputation, her personal reputation is merely interesting to the organization. A leader who never pays a bribe is of little benefit to the organization if she doesn’t put in place processes to prevent corrupt behavior by others.

A leader who allows his organization’s integrity and reputation to suffer will also see his business suffer. His requests for additional headcount, for funding, for equipment will be denied by higher-ups, who can no longer trust his organization. If such a leader didn’t lose his job for failing to protect the organization’s integrity in the first place, he’s likely to lose it soon for not meeting operational goals.

This is one of the most compelling perspective I have seen to describe the value of ethics & compliance to business leaders. It turns on its head the too-oft used expression “Good ethics is good business,” which sounds good but is far from a call to action.

Ethical leaders understand that their personal integrity is merely an asset, a compass, a guide to creating organizational integrity.

The real work remains to be done.

Culture and personal integrity

Let’s say you are not much of a joke teller and you join a small organization where everyone has a blast sharing hilarious jokes. Chances are you’ll start paying attention to jokes you hear outside of work and will share them with colleagues at the office. You want to fit in. We all want to fit in. A few thousand years ago, not fitting in and being an outcast meant a certain death. So we are hardwired to fit in.

Let’s say you do like telling jokes and you keep your materials very clean. Now you join a small organization where they laugh loudest at mildly inappropriate jokes. Might your repertoire change a bit? It probably will. After all, everyone seems to think it’s fine and they’ve been telling these jokes for years.

You see where I’m going with this? What jokes are acceptable, how we recruit talent from competitors, how we keep our books, how we discipline, what gifts we allow our employees to accept from suppliers or give to customers – all we do is greatly influenced by the culture of the organization. The culture has such a strong pull that the best of us will change our behavior to conform. The longer we stay in orbit, the more normal certain things will feel, even if those things would have shocked us a few years ago. And when we assimilate, we reinforce the culture for everyone else.

When our livelihood depends on fitting in, it is very difficult to stand against the machine. So for those (college seniors) out there looking for a job, my advice is this: place the highest importance on the culture of the organization you are considering joining. Your happiness, your integrity, your sense of self are at stake. You want to join an organization that shares your values and whose sense of purpose is aligned with yours. With such an alignment, all your energies can be focused on growth and contribution.

The mental toughness of ethical leaders

In her post titled “Are you tough enough?”, Linda Henman describes what it takes to be a winner. How does this apply to ethical leaders?

Self-belief

We must believe in our ability and courage to make the right decision, even when it’s the hard decision.

Desire and motivation

We must want to win the right way. We look for markets that allow us to win on the merits of our products and services, following processes that don’t encourage bad behavior.

Performance-related focus

We see our ability to promote trust and integrity as a competitive advantage. Customers understand that how we do things is just as important to us as what we do.

Lifestyle-related focus

Ethical leaders behave with integrity on and off the job. We don’t flip a switch when we head to work in the morning.

A capacity to deal with competition-related pressure (external) and anxiety (internal)

In a world filled with VUCA, we understand that adaptive performance is more important than tactical performance. We recognize that we have a choice and that we labor for something greater than ourselves.

People like us don’t cheat

Organizations with a strong safety culture never tell their employees that they must comply with safety measures to avoid government penalties. Instead, they speak of the importance of everyone returning to their families every night in good health.

Yet, when it comes to corruption, most organizations wave the latest billion-dollar fine in front of their employees as if avoiding such fines was the driver for honest behavior. Would they not care if the fines were smaller?

Ethical leaders tell their followers “People like us don’t cheat, lie, or steal. We win the right way, on the merit of our products and services. Others can trust us because we perform with integrity, always.”

Lazy managers use scare tactics. Ethical leaders inspire principled performance.