You tell your employee on March 1 that she will get her bonus check on April 1.

On March 15, she resigns with an effective date of April 15. Do you still pay her bonus? It depends what the bonus is for. Is it a reward for good work or is it a retention tool?

“What is it for?” and “Who is it for?” are key business practices questions. They also apply to E&C programs. Who are you writing this policy for? What is this training for? Who is the audience for this communication?

Often times, we tell employees that these things are for them, when in fact they were created with the regulators or the shareholders in mind. Employees feel the disconnect, and they don’t engage.

There is value in creating E&C programs that are responsive to regulators’ expectations. But if we want them to resonate with employees, we need to be open about who and what they are for.

With every new policy, training, or communication that we are ready to deploy, we need to ask ourselves: “Will our employees now be more likely to speak up if they see a problem?”

If the answer is not a clear yes, our work is not done.

The rabbi who helped his congregants escape the hostage standoff in Texas a few days ago credited the security training he received for keeping everyone alive.

When we practice something in advance, we can think more clearly when facing the real situation. We can also act more quickly. This is why military personnel, firefighters, and other first responders use most of their spare time to practice over and over again.

In corporate ethics, we can do the same thing. We can practice, in advance, how to respond to ethical dilemmas. Perhaps the best training in this area comes from Mary Gentile with her book Giving Voice to Values. Gentile starts with the assumption that most of us know the difference between right and wrong. What we need, she says, is to practice, in advance, how we would respond if we were asked to lie, cheat or steal – or if we observed someone else doing these things. If properly trained, we are more likely to respond in a way that will keep us and the company safe when the real thing happens.

Don’t wait to be “held hostage” by an unethical situation at work before you learn how to escape it.

Imagine an old-fashioned weight scale.

Now imagine using it to measure who your compliance training is for.

On one side, you would place weights on behalf of your employees, measuring your desire to help them do their job compliantly.

On the other side, you would place weights measuring your desire to meet the enforcement authorities’ requirements, to track completions, to automate reminders, to please your board, etc.

Which way would the scale tip?

Just before the pandemic, a German flutist experimented with the idea of “one-to-one concerts.”

One artist. One audience member.

When the pandemic hit, it became immediately clear that these concerts could go on. Not only were the performances immune to COVID-19, they also fed that hunger for connection we all felt. There have now been concerts across Europe, Asia, Australia and the US.

An art reporter attended one of these performances in Brooklyn earlier this year. Sitting atop a building, he listened to a solo viola playing Bach and described it as “almost overwhelming, emotionally and musically.” He later said “It may have been only 10 minutes, but I’ll be thinking about my One-to-One Concert […] for a long time to come.” (I recommend you listen to the 3-minute audio report.)

This concept reminded me of my choice to introduce my company’s ethics & compliance program to each new employee during one-on-one meetings, rather than join other functions who batch new-employee training once every quarter. Let me rush into saying that I do not claim to be a virtuoso at what I do, or that new employees have an emotionally overwhelming experience listening me describe our corporate values! But I do believe that employees are more likely to reach out to me when they have ethical concerns later on if we have met one-on-one soon after they’ve joined. And I have been told, by several employees, sometime years after we first met, how impressed they were to have been invited to this one-on-one alone-time.

Most artists can’t survive on one-to-one concerts. Their need to perform in front of larger audiences is real.

The same need is not necessarily present in ethical leadership.

Some employees do not have to make any decisions on the job.

Until they do.

The employee that simply needs to stock the shelves at the grocery store might one day notice that the receiving supervisor is taking small bribes from suppliers who want priority in getting their trucks unloaded. That employee with a “no-decision job” now has a decision to make.

Do you have such employees working for you? Do you share your company values with them? Do you provide ethical decision-making training to them? Do you tell them about your reporting channels?

Low-level, no-decision employees are often front-line employees. Which means they are close to the customers, to the suppliers, even to the competitors. These interactions can be risky.

Removing decision-making from employees can reduce some risks, but it can also create others.