The Culture of Ethics
By Christine V. Williams
As 2018 quickly approaches, many companies are visiting or revisiting their code of conduct and/or business ethics code. Here are a few pointers and look for more coming in the following weeks:
• Know who is giving you advice on an ethics and compliance program. Is it a first timer or someone experienced and knowledgeable in the field. Asking questions moves you in the right direction. As someone who has written codes for quite a while and who actually authored her first national ethics code used across industry in 2012, I welcome the question.
• Be prepared for the question: what is your desired result and how are you most comfortable getting there? Many companies want to educate employees, create a culture of ethics, and be able to defend based on federal mitigation standards in case a federal or state lawsuit is ever brought against them.
• Do you set a strong and repeated tone from the top? Most employees and the lack of reporting may be due to the tone and perception of lack of follow-up on concerns/complaints.
• If you have a system in place, how do you stress test it? For each component of your business (accounting, cyber, HR, federal work, state work, commercial work) think about your system and how to see if it is working and how it could work better.
Some interesting facts from Ethisphere, which you likely have heard me refer to as ranking the most Ethical Companies and Compliance Programs and a good program, a/k/the World’s Most Ethical Companies (WEMA):
• WEMA companies Measure Ethical Compliance Using 5 Different Sources or Inputs, including, Multiple modalities-inside and outside sources, and WEMA companies do not just rely on surveys.
• Dedicated surveys do play a role, with 57 percent of WEMA’s using surveys to gauge perception of an ethical atmosphere.
• 62 percent of ethical complaints go to the immediate supervisor, 32 percent to HR, and only 8 percent to a hotline and 7 percent to a portal.
• Almost a quarter of employees indicate feeling some level of pressure to compromise policy, the Code or law to achieve business goals.
• Twenty percent of employees do not believe the complaints will be investigated.
• “Nothing will happen” is closely to tied with fear of retaliation as a reason not to report (fear and a lack of transparency are leading causes for why employees are not willing to report).
This is the first in a series of compliance and code type updates as well as statistics on how to make your company operate at its most efficient while coloring within the lines becomes a strong cultural value that is fostered at all levels.