Table of Contents
Jacek Szemryk (jszemryk@gmail.com) is Supervisor of Audit and Compliance at UPS in Wroclaw, Poland.
Ethics. This word has been used in business for ages. Nowadays, within the compliance world, this word appears more often than ever. Is it because the business world struggles to remain ethical, or maybe business realized that the role of ethics within a business is indeed essential?
Once you as a business owner, CEO, or a compliance professional realize that something must be done with ethics within your organization, another question arises: How can we ensure our people maintain ethical practices for the next months, years, or decades? Can we train people once at the beginning of their career within our organization and remain confident that will provide us ethical employees?
Best practices
My view is far from that, and the suggestions below will direct you to the practices that will enable your organization to enhance the ethical performance of your personnel.
Tone from the top
The phrase is used so notoriously that in some organizations it presents no more value. Ask your CEO or ask yourself as a compliance officer, “Do you present ethical behavior throughout your actions at work and in life?” “Do we treat ethical performance as another business aspect that simply must be achieved?” Or is it something more than that? Teaching or preaching ethics should be a mission of the preachers and, without true belief in that, not much can be achieved in the long run.
Value-added trainings
By valuable, I mean two aspects. First of all, the ethics and compliance trainings must be as much personalized to the job type as possible. The current trend in most organizations is to deliver online training to their employees. The positive side of it is the convenience in terms of time and place when watching the trainings. We may easily compare it to the win of video on demand (VOD) over the traditional cable TV.
The risk, however, is that the viewers who complete the training at work will have a tendency to click the “next” button on the online slides. Personalization will encourage listeners/viewers to put themselves in the shoes of the training scenario character. Case studies are necessary to engage the viewers in active participation, as well as tests with more than three questions that are easy enough to be answered without completing the lesson. Make the tests more demanding.
Secondly, the training must be updated. In 2018, employees should be presented case studies where GDPR, cybercrime, and other current risks are real. Last but not least, make the trainings recurring. An annual cycle of personalized training should do the trick.
Procedures and guidelines
A well-organized company cannot live without its own internal regulation. In terms of compliance and ethics, a code of business conduct is a must. After providing initial and refresher trainings to your staff, they need a document to refer to. What I found really useful at the beginning of my career was a code of business conduct supported by cases studies analysis. Ideally, those scenarios are tailored to the departments that should receive training. The employees may refer to the cases, analyze them, and then try to apply the solutions to their own issues in their departments. The analysis is often eye-opening to the staff as they realize that the world is not always black and white, and some ethical decisions are tough to make.
Voicing concerns
Both the helpline and surveys must be anonymous. A helpline is available now in more and more companies, so it is essential to make your staff aware of the possibility to voice their concerns. Posters in the popular places (e.g., canteens, smoking rooms, lifts) are a good start. If you employ representatives of different nationalities or do business worldwide, provide the opportunity to speak in their local language, because this is always more comfortable for the speaker. The potential language barrier may decrease the number of reported cases.
Penalties
Having trained your employees, you as a director or chief compliance officer want to believe the entire personnel applies the ethical standards. Nevertheless, you must be secured in case they don’t. It is important to make employees aware of the potential penalties for unethical behavior. If your local law provides sufficient restrictions, it is recommended to refer to them. Otherwise, state clearly the potential penalties in your work regulation or other procedures known to the entire personnel.
Communication
Finally, ethics cannot be separated from other areas of your business. The ethical work requirement needs to be emphasized by employees on all levels of your organization as well as in all departments. Compliance and ethics cannot be referred to only once a year when the time comes to complete trainings or provide the organization key performance indicators (KPIs). Compliance professionals need to be contacted on a regular basis as advisors to other departments. When your organization plans an expansion or acquisition, consider inviting a compliance representative to the project to have the “ethics voice” heard from the very beginning of the project by all members of the team.
