Building a Culture-Changing E&C Program: Six Essentials

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Compliance programs are effective only to the degree that they help build and support a strong organizational culture. So what does a strong corporate culture look like? And what ethics and compliance tools can help support it?

Following are some essential characteristics we have observed in companies whose ethics and compliance program and corporate culture are delivering significant value. 

1) Clear and consistent limits of acceptable behavior.

Cultures focused on doing the right thing have clear, written standards of behavior. These standards include codes of conduct, employee handbooks, and policies and procedures that clearly articulate what is and is not acceptable business conduct—and the consequences for stepping outside the limits.

To manage these policies and procedures, leading companies employ policy management solutions to automate and track the development, deployment and employee attestation and certification. Best in class policy management tools enable comprehension quizzing, automated reminders and links to required training—or even embedded training. These efficiencies gained through policy management strengthen the standards as a risk control while lifting the enormous time burden of manual processes off of the compliance staff.

2) Board and management are committed to ethics and compliance.

From the top leader to the lowest level supervisor, all company leaders actively support the program. They look for opportunities to talk about ethics and compliance issues with their staff and often using brief training and awareness tools to guide discussion. They are the first to complete policy and training requirements and they ensure their people do it too. These leaders advocate speaking up about concerns and promote the use of open door reporting, web-reporting and anonymous hotlines to make sure employees understand their options for raising concerns.

3) No marginalization of ethics, compliance and legal requirements—or staff.

Compliance professionals must involve staff outside of the traditional “rule-making” functions to build and sustain a strong corporate culture. Ethical business practices must remain an integral part of everyone’s responsibilities.

Technical tools can help with this in several ways. Policy management software can ensure that appropriate functional staff is involved where it makes sense with creating, reviewing, and submitting standards for final approval.Training and awareness materials educate employees on business values, ethics, compliance and legal responsibilities, and can keep up a cadence of reinforcement.

Those that work with third parties can play an important role by vetting and monitoring these partners with an automated third party management system that continuously monitors for red flags in a proactive, rather than reactive manner. And rather than tightly limit access to the case management tool, include human resources, security, risk management and other functions that may field employee reports or conduct investigations.

4) Employees can comfortably ask questions and raise concerns.

The most common reasons employees do not speak up are (1) fear of retaliation and (2) the belief that nothing will be done about the issue. Our extensive benchmarking studies have shown that fear of retaliation greatly outweighs actual reports of retaliation. And often, raised issues are appropriately handled, but the reporter is never informed of the outcome, even in summary fashion.

These two hurdles to speaking up can be mitigated by education—for managers and employees. Online training and awareness solutions help management understand their responsibilities regarding proper handling of complaints.

Employees also benefit from education by learning about their own obligation to speak up.The thorny subject of retaliation—what it looks like, what to do about it, and protecting against it—is a critically important learning topic. Education works to prevent these speak up inhibitors from taking root in the culture and a comprehensive hotline and incident management solution provides a way to detect and track correction of retaliation and non-action when it is reported.

5) Goals and incentives do not exert pressure on employees to step over the line.

Human resource professionals may create balanced performance objectives for all employees that make it clear that the company cares not just that goals are achieved, but how they are achieved. But how do you know if management or peers are exerting subtle pressure or offering incentives to bend the rules in pursuit of the numbers? Again, training and awareness plays a preventative role. When combined with hotline and case management tools to remediate reports and detect patterns, it creates a strong safety net against the subtle influence of “Do whatever it takes to meet the numbers.”

6) Poor conduct is not tolerated.

Nothing sows cynicism faster in the workplace than a senior leader or sales superstar getting away with misconduct. Employees consider fair or unfair treatment to be a reflection of the organization’s level of integrity. This makes it especially important to discipline misconduct consistently and advertise that the organization takes misconduct seriously by publishing redacted cases internally. A good case management system, used by all staff who implement discipline and other corrective actions, is an indispensable tool for ensuring consistency for similar violations—and for reporting outcomes that can be shared broadly to promote desired conduct.

Bottom Line:

Technical tools can aid ethics and compliance efforts by increasing efficiency, creating documentation and connecting with each other to enable just-in-time training, database inquiry, and policy consultation. The ultimate benefit is increased program effectiveness that supports a strong organizational culture of integrity.


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