Compliance Communications (Part 2): Integrity is Everyone’s Job.
— February 10th, 2020
In my last blog, I talked about how we must underpin people’s good intentions with a culture of integrity and ethical guidance.
Here, I’d like to continue the discussion by looking at training your organization’s integrity muscle, adding some technicalities for communicators, and sharing one final thought on the “bad apples”.
Spoiler alert: I don’t think there’s a one-size-fits-all standard formula to get your message on ethics and integrity out to employees.
As always in communications, it is paramount to understand which mix of messages, media, and channels, as well as timing generally work for your organization and to apply your communicator expertise in change management.
Training the Integrity Muscle
One thing’s for sure though: Building and maintaining your organization's 'integrity muscle’ is like training to run a marathon.
It takes perseverance, continuous coaching, and physical training, and the flexibility to pragmatically adapt to changing internal and external conditions.In short: it never ends, and isolated one-off efforts will not hit the mark.
As a communicator, I therefore strongly recommend you don’t act in isolation. Next to making friends with leaders and fellow communicators, your policy makers and field compliance officers, another relationship you may want to build is that with your learning team.
Most employees will not be faced with severe ethical dilemmas daily. Also, when those dilemmas occur, it often isn’t obvious. Hardly ever will someone approach us with a suitcase filled with dollar bills – a scene we might expect if we’ve watched too many Hollywood movies!
Keeping awareness and skill levels at a constant high therefore is important and likely more relevant to ethics than any other aspect in business because we oftentimes cannot train our integrity muscle on-the-go, as we do with other facets of our work.
This is why I believe in the power of teaming continuous communication with regular training: It’s about keeping organizational knowledge fresh and relevant, enabling your organization to recognize even the most subtle signs of unethical behavior and empower it to act on them in the right way at any given point in time.
A Couple of Technicalities
There are a couple of communication technicalities I would like to highlight because I have found them to be unique to or at least more predominant in the context of compliance and ethics. This is not an exhaustive list, but an attempt to provide those examples that I consider most worthwhile to know about.
Planning for Acknowledgement
Policies may require formal acknowledgment of receipt and/or adherence by all or certain employee groups. Often, this is performed using a system-based approach (e.g. via your standard learning management system). In a production-based environment or depending on local legislation, a paper-based approach might prevail.
While the definition of the appropriate process may be with your policy makers and human resources department, and you might not even actively be involved in its execution, it is one key element I recommend you consider in your overall communication planning.
Supporting Due Diligence
Just like your organization will vet partners, suppliers, and other third parties before entering in any formal engagement, many third parties will vet you and your company history for ethical aspects.
As a communicator, drafting reactive statements for the media and keeping a history of key external statements made will not be new to you.
In the context of compliance, you may also need to consider supporting field compliance officers with such statements in the context of due diligence enquiries on your organization.
Preparing to Report
You’re likely already an expert in communication-related key performance indicators and reporting to demonstrate the return of investment in that latest campaign that you launched. In the compliance environment, you’ll need to take reporting further.
Whether it’s your corporate internal auditors or external ones, be prepared for ad hoc requests to provide evidence of your compliance communication activities.
I recommend building an archive of your communication plans, collateral used in their execution, as well as proof of execution such as dated newsletters, meeting invites and agendas, and so on.
In addition, compliance will (hopefully) be a topic prioritized by your senior executives and supervisory board.
Think about developing quick reference, executive summary formats – not only to sell the awesomeness of your work but also to flag those aspects where they need to step up and take their engagement to the next level.
In the context of sustainability and corporate responsibility, a culture of integrity and ethical business is gaining more and more importance with, for instance, investors, business partners, and potential employees.
Reporting therefore may be necessary – or an opportunity to make your point – in annual reports, corporate responsibility reports, or in the context of external corporate responsibility rankings.
One Final Thought
In my daily work, I tend to focus on that vast majority of good people and how to help them to act on their intention to make decent choices. However, where there’s light, there’s also darkness: The few “bad apples” as I like to call them.
Those few individuals who are out there for their personal gain – inside your own organization, or at your suppliers, partners, or other third parties you interact with. Those, whose actions cause exponential harm to everyone else around them.
I believe they will be inclined to wrong-doing no matter what. I, therefore, trust in the ability of constantly evolving control systems and company processes for uncompromising uncovering, investigations, and consequences.
On top, here’s what all of us can do: If we stand together, upholding our culture of integrity and acting on it, we can send a clear message of intolerance for wrong-doing: We don’t settle for anything less than our standards, we are vigilant, and we will act on our convictions.
Remember, whatever your job, we’re all in the trust business and that’s why integrity is everyone’s job: it takes the whole village.