Lynda Hilliard (firstname.lastname@example.org) is Principal of Hilliard Compliance Consulting in Mount Shasta, CA.
The basis of our ethical foundation is shifting below us. Questionable conduct, ranging from losing trust in the decision-making of our leadership to large-scale scandals threatening reputations and organizational viability, is happening more frequently! The acceptance of questionable business practices and a perceived need to get ahead at any cost is taking its toll on business and compliance leaders. We need to stand strong. We need to be there as role models for our employees and provide the structure and foundation they need to continue their valuable work and know that what they are doing reflects a positive ethical culture.
Our organization’s code of conduct and “tone at the top” provide an initial barrier to prevent unethical behavior. However, constant business and environmental pressures support cutting ethical decision-making corners to maintain and/or enhance financial success. What can we do as compliance leaders to strengthen those invisible shields and maintain the integrity of our mission of ethical behavior?
The Wall Street Journal’s CFO Journal blog of January 19, 2018, reported an interview with Keith Darcy, an independent senior advisor to Deloitte & Touche LLP’s Regulatory and Operational Risk practice. The interview outlined a number of challenges faced by established compliance and ethics programs and presented suggestions on how to address those obstacles. Several of the key steps outlined by Mr. Darcy include:
Define the culture: Continue to monitor the culture through surveys and culture assessments.
Instill culture and values throughout the organization: Ensure that all points of the organization receive attention, including far-flung offices.
Handle naysayers: Identify and educate those who have not bought into the program and redirect negative behaviors.
Battle values fatigue: Develop a marketing strategy to keep ethical communications fresh and new to keep employees engaged in the process.
Address leadership flux: Even though leaders may move on, there is a need to ensure that new leaders are hired who are a cultural fit with the organization.
Appeal to a cross-generational workforce: Instilling a consistent set of values and standards that addresses the needs of a diverse and multi-dimensional workforce helps to solidify a strong ethical culture.
By clearly and consciously incorporating our organization’s mission and values into daily operations, we can establish practices that inherently reinforce and visibly enhance the ethical culture of the organization as well as demonstrate commitment by leadership.