Compliance Communications (Part 1): Talk Ethics to Me!
— February 3rd, 2021
Call me an idealist, but I run on the deep-rooted belief that the vast part of humanity is intrinsically committed to integrity – to making decent and ethical choices even when no one is watching.
With good people everywhere, how come that at the same time I find it worthwhile to spend a good portion of my communications career in legal and compliance functions?
Quite simply, because good people aren’t immune to making bad choices. Good intentions need to be underpinned by culture, guidance, and skill.
A Culture of Integrity
Regardless of our industry, all of us are in the ‘trust business’: just like our personal relationships, business interactions are built on trust. Integrity is a key ingredient in building that rapport: It’s part of why others may choose to do business with us. It’s also a reason why we decide to do business with others.
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If companies cannot be trusted to live up to the highest ethical standards – and cannot trust that potential partner, suppliers, and other third parties do the same, it will affect the opportunities for corporate and societal evolution.
Trust is also the foundation for individuals – most importantly our employees – to confidently speak up, without fear of retaliation, when they become aware of wrong-doing and inconvenient truths.
To me, the ‘tone-at-the-top’ is therefore one essential element in building and sustaining a culture of integrity, and ultimately trust.
We need senior leaders to set that cultural framework – potentially in correlation with your defined corporate values – by continuously outlining why integrity is important for corporate sustainability and what integrity means in our organizational context – regardless of varying national cultural standards. In short: how we earn to be trusted around the world.
Actions, however, speak louder than words. Their commitment to such a culture needs to be evident in their daily doing.
Yet, matching perceived integrity and actual integrity is a struggle: particularly in large corporations, very few employees will ever directly interact with a board member, let alone report to one: naturally, they will have little opportunity to experience ethical behavior by C-Suite members.
As an employee, I’ve always appreciated when in town hall meetings senior leaders shared their personal experiences with ethical dilemmas throughout their career and how they have resolved them by asking the right questions and taking the right actions.
Their commitment to integrity to me has also been demonstrated through ‘tales from the hotline’ – anonymized real-life examples of corporate compliance investigations triggered, for instance, via reports to the whistleblowing hotline.
These may not be shared by leaders directly, but I’ve always perceived them as a strong sign that I could trust that the organization and its executives walk the talk.
- First, these stories provide a sense of relevance that ethical dilemmas exist and require everyone’s attention and action. I also find that those that involve whistleblowing show how all of us can be everyday heroes simply by speaking up for the right thing.
- Second, they showcase seemingly innocent ethical traps anyone could easily fall into unintentionally.
- Third, they demonstrate the support employees receive in the resolution of ethical dilemmas that they have been involuntarily faced with, but also state the uncompromising company actions when individuals have acted with intention.
- Lastly, they can give context by explaining the oftentimes atrocious consequences of the seemingly isolated actions of one “bad apple” can have on our business, its reputation, and consequently all of us and the communities in which we operate. The documentary ‘The Struggle Against Corruption’ by the United Nations Office on Drugs and Crime (UNODC) is a great resource to learn more about the wider societal impact of unethical practices.
Another aspect that requires attention in the context of senior leaders is the congruence between their ethical and general business expectations – achievement of sales targets is a classic: if for your organization it is unacceptable to miss those targets, chances are high for good people to knowingly engage in a shady deal after all.
I’d like to advocate for making the effort to understand why targets have been missed and to formally interlink ethical and business goals, and commission schemes.
While the C-Suite and other senior leaders set the tone, culture really is defined by our day-to-day interactions, by ourselves and those in our immediate surroundings.
Employee survey questions on trust towards our immediate managers and their display of ethical behavior provide helpful indications of the state of the corporation.
As communicators, we therefore also must pay attention to the ‘tone-at-the-middle’. We must ask how we can contribute to enable the average manager to confidently speak and act on ethical aspects in an integrated manner, rather than a bolt-on. The same question rings true for the broad employee base, because shaping and sustaining a culture of integrity is everyone’s job.
With some companies doing business in almost every country around the globe, I think it’s fair to assume that it’s impossible for their average manager and employee to have detailed knowledge of all the laws and regulations they are required to adhere to – and are protected by – worldwide.
That’s why I find the idea of corporate policies so appealing. Yes, agreed, most of them aren’t the most entertaining pieces for a reader to consume. BUT: despite not being likely to win an award from the writers’ guild, policies and their authors deserve appreciation.
My abridged definition is that they combine the world’s strictest legal and regulatory aspects on a certain topic, say corruption for instance, and turn them into a compact set of corporate guardrails for anyone without having to become an expert on the topic at hand.
Simply by the fact that they exist, I can trust that someone has identified the key risks for the business and its people, assessed the severity of these risks, and put the tools and processes in place to help me and others navigate them – or steering away from them entirely – as safely as possible.
In short: policies rock! Said no one ever – unfortunately. So, here’s a thought: next time a new policy needs to be communicated in your organization, how are you going to position it?
Instead of talking about “yet another set of rules for things we mustn’t do”, let’s take it as a starting point to also talk about desired behaviors and how they’re helping us to be around for the long haul.
Also, – and I certainly don’t recommend messing with the legal aspects of a policy or turning it into a fluffy marketing brochure – get involved to make policies “on brand”.
I encourage you to team up with your policy-makers to elevate the appeal of their documents with your company’s visual and verbal identity. Employee Codes of Conduct have become great examples for such collaboration.
Farmers of Goodness
Upon my departure from the agricultural industry, one of my then-managers gave me a t-shirt she had designed. It read “Farmer of Goodness”. I like the term because it’s got something down-to-earth, hands-on, and honest about it.
That’s why I bring it up today: Likely the most underrated heroes in compliance communication are the field compliance officers. To me, they are true ‘Farmers of Goodness’!
Let’s face it: formal ethical guidance is great but if you had to name just one average employee or leader knowing all your company’s policies by heart, inside out, you’d be doomed to fail with flying colors. That’s where the compliance field team comes in.
Typically located in-country and/or working very closely with various market units across several countries, they are the face of ethics and compliance, the formal stewards of integrity locally. I believe one of the key choices they’ve got to make is about their own positioning.
Do they want to live up to the compliance stigma of policing and controlling? Or, be that approachable expert who truly understands and cares about your business challenges, who’s got your back, and coaches you to ensure your actions are sustainable and in line with corporate guardrails – and thus the law – and processes.
I am fortunate to say that most compliance officers I have met along the way opt for the latter; and in reality, spend the majority of their time on business consulting and undertaking preventive actions such as training and communication.
If nothing else, I recommend you take time for a coffee chat with your compliance officer today and ask them about their challenges. I have no doubt: the conversation will trigger plenty of ideas on how you can support them in bringing across their messages with ease and impact.
Read more next week, on Wednesday, February 10th, in Val’s follow-up blog ‘Compliance Communications (Part 2): Integrity is Everyone’s Job’