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Ethics at the company level begin with ethics at the employee level
In a recent StarBlog, we talked about how—even in this age of automated compliance platforms—compliance officers remain first and foremost investigators. We gave you five ways to spot impending unethical behavior in the workplace, as driven by personal financial turmoil.
In part two of this series, we're discussing techniques to instill, inspire, and strengthen ethical behavior, starting with the assumption that an effective compliance program begins at the level of corporate culture. Or, even more fundamentally, at the individual level. Because in the end, isn't it really all the same?
At first blush it may seem a strange idea, that you need to define ethics. Don't we all know right from wrong? But from an organizational standpoint it needs to be done. Consider the broader culture. Ethics can vary widely, to the point one group may consider another group's ethics, well, completely unethical.
So firm ethics are worth thinking long and hard about. The effort must be taken seriously, with the involvement of upper management. The core beliefs and values must have buy-in, and better yet be driven by firm leadership. And even then it's not all top down. It's worth taking the pulse of the organization and considering what's already there, what's working or not working.
Then, write it down. Having a document, analog or digital, to refer to and spend quality time with matters: whether it's the Magna Carta, a family fridge posting, or an enterprise financial firm's ethos.
Why wouldn't you hire ethical people, you might ask. But what this notion is really getting at is, new hires should already understand why ethics are important. You shouldn't have to teach that. You should only have to teach how your organization handles ethics, and highlight the values and ideals most important to you. A popular hiring philosophy is: hire for personality, train for skills. This is similar. And a potential new hire can be vetted for ethics just like for anything else.
Once your company has found someone with a firm grounding in ethics, consider the onboarding process. This is the perfect opportunity to begin explaining and instilling the organization's ethical framework. Compliance officers should review materials used in the onboarding process and ensure they have an appropriate E&C focus.
Compliance officers should also consider meeting with new employees as part of the onboarding process. What better way to stress the importance of ethics to the organization than taking the time to meet the new hire? You're also putting a face to E&C, therefore making the whole concept more personal. And ethics is nothing if not personal.
In the military, it's mid-level leadership who carry the greatest responsibility for seeing things through. Generals make policy, but it's the majors and lieutenants who turn that policy into practice. And while privates and sergeants literally get the job done, it's the captains and colonels who ride herd and make sure it gets done.
Similarly in companies, it's middle managers who are tasked with turning policy into practice. As such, it's worth keeping a close eye on them. It's probably at this level that professional fatigue is most likely to set in, with managers having to deal with input from both ends of the organizational hierarchy. Give middle managers the tools they need to succeed: training on how to be better managers and, of course, training on the issues of ethics and compliance important to their daily work.
Offer praise, when warranted, and direction, always. No one is ever entirely beyond mentoring. Management training for c-suite executives is a thriving business for a reason. Finally, sit in on the presentations your front-line E&C warriors give to their reports, at least occasionally. Not only will it keep them sharp, it clearly demonstrates you're concerned about staying in touch with what's going on in their world.
A few bad apples can spoil the bunch. You are the company you keep. There's a reason these sayings persist. Negativity is catchy. Like a virus, it can be passed on. Malcontents can do a great deal of damage to company culture: undoing progress at the macro level by sabotaging it at the micro level.
It doesn't take much, or many. Back to the few bad apples. And once the poison has seeped out, it can wend its way into peoples' thinking. Then, how do you kill an idea? Compliance needs to treat malcontents as a threat to corporate culture and therefore as a threat to ethical culture. If employees don't see their company as an entity they can be proud of and take pride in working for, there's less reason to be watchful over it. To value it and care for it. To be alert for someone who might decide to take advantage of the firm for personal benefit, or to attempt it themselves.
A compliance officer with her finger on the organizational pulse, who gets out of her office on a regular basis to mix with employees above and below her pay grade, can pick up on this sort of thing. Once identified, malcontents should be pulled aside and spoken to. If they won't make the effort to turn their thinking and actions around, maybe they'd be better off working somewhere else.
Marketers are great believers in repetition. It's established a person needs to see or hear a message anywhere from 5 to 30 times before it sinks in and makes the crucial difference when needed. For example: when you decide it's time to buy a car and that persistent stream of Volkswagen advertising finally leads you onto the local lot, without you necessarily aware you were influenced in any way. In fact, the best marketing and advertising would have you believe you came up with the idea all on your own.
The need for repetition thus acknowledged, it's critical to vary the medium. If you hit people over and over with the same message in the same format, say via mail, they will likely start to tune it out. So use every tool at your disposal to get your critical messages out to the company. Email. Social media. Intranets. Newsletters. Flyers. Banners in the lunchroom. Speaker events, perhaps paired with treats. The message itself could be woven into a story. Stories help people relate. As a species, we're evolutionarily programmed to respond to stories.
At a recent compliance roundtable, your StarCompliance blogger overheard a compliance officer talk about his method—as a certification deadline loomed—of ramping up the reminder email frequency to 10 emails per day for procrastinators. He got results, but his case might be the exception that proves the rule. Finally, consider whether the message you're trying to get across is really necessary. E&C fatigue can take many shapes, and if employees feel you're always "bothering" them that's another reason to tune out.
