A real-life situation recently provided powerful evidence of the value—and effectiveness—of ethics and compliance training and communication.
When scientists want to prove the effect of something such as, for example, a new drug, they often conduct a study comparing two groups. Ideally, the two groups are as similar as possible to each other, with the only meaningful difference being the factor being studied (e.g., only one group would get the new drug).
Such a scientific approach is very difficult to implement, however, with ethics and compliance programs. And yet my team recently came across a situation that came surprisingly close.
The Subjects of Our Comparison: “Site A” and “Site B”
We were recently engaged to assess the ethics and compliance culture of a global company. In the course of our company-wide culture assessment, we visited a number of offices around the world.
Of the sites we visited, there were two (let’s call them “Site A” and “Site B”) that were similar in many ways. Both were new operations, with most employees having been on board for only six months or so; both provided relatively similar services; and both were in the same country.
Of course, both Site A and Site B were also subject to the same policies, Code of Conduct, etc., and had the same company executives.
So, all else being equal, we might expect similar results of the cultural assessment for the two sites, right?
The Surprising—and Significant—Differences Between the Two Similar Sites
On a number of the measures in our culture assessment, however, the two sites differed significantly.
For example, the employees at Site A:
- Knew more about the company’s ethics and compliance helpline than the other
- Had greater confidence that they would not experience retaliation if they raised a concern (through the helpline or through another channel); and
- Felt more strongly that their managers and senior leaders lived up to the company’s values.
In some cases the differences were very large. For example, the percentage of employees at Site A who reported that they would not fear retaliation if they raised an issue was more than 50 percent greater than the percentage of employees at Site B who felt that way.
Why the Differences?
At first we were stumped by how there could be such significant differences in ethics and compliance program awareness between the two sites. However, in discussing the results with the client, we learned that, for a handful of business reasons, Site A had received significantly more training and communication about the organization’s ethics program, helpline, and other ethics and compliance program components than Site B.
This, of course, explains why Site A knew more about the helpline than Site B. But it also shows the effectiveness of the training and communications—with less of it, the employees at Site B were less aware of the helpline and how it worked.
Perhaps much more interesting, however, is the fact that Site A’s results on a number of other measures were also significantly more positive, including confidence that management would do the right thing if alerted to an ethics or compliance violation. This, it would seem, is a collateral effect of the training and communications.
Implications for Improving Ethics and Compliance Program Effectiveness
With management talking and communicating about the ethics program more often—and by taking employees away from their regular work to do the training—the company was demonstrating that ethics and compliance matters.
The bottom line: the residual effect of all of the attention given to ethics and compliance was that employees at Site A had an overall more positive impression of the company’s ethical culture than employees at Site B.
Of course, this was not a controlled, scientific study, and it’s possible that other factors influenced the outcomes somewhat. Nonetheless, the contrast between the two sites offers strong evidence that quality training and communications make a real and substantial difference—and lead to a stronger culture of compliance.