When an organisation’s policies, procedures, rewards or even its Code of Conduct are in conflict with its culture, culture wins. Therefore, in order to have an effective ethics and compliance programme, an organisation must pay as much attention to culture as it does to policies, training, auditing and other programme elements.
Compliance supports the strategic goals and mission of an organisation just as much as any other department or function. Achieving an effective ethics and compliance programme requires more than simply adding rules and additional layers of controls. Successful programmes are integrated efforts that align financial and compliance requirements with the organisation’s mission and values.
Forward thinking organisations strive to build a culture where all employees know that doing the right thing is expected, understand the standards that apply to them and are confident their management is committed to operating with integrity. These same employees should feel empowered to raise concerns about misconduct without fear of retaliation and believe their concerns will be addressed.
If doing the right thing is the expected practice, behaviour that is unethical or otherwise misaligned with organisational standards will stand out and can be more easily addressed. The only way to know this by assessing the organisation’s culture as part of the assessment of the ethics and compliance programme.
Answer the following questions to see if your culture is one that promotes ethics and respect.
- Is all staff held equally responsible for their actions?
- Does doing things right trump revenue and company goals when the rubber hits the road? Is unethical behaviour clearly seen as out of bounds?
- Do employees believe that management will take appropriate action if misconduct is communicated to them?
- Do employees believe they can raise issues to management or the 0800 number without fear of retaliation?
- Is the program viewed as a paper programme or as a genuine commitment?