Driving a High Touch International E&C Strategy

October 4, 2016 Marsha Ershaghi Hames

Pictured are LRN's Marsha Ershaghi, Priceline's Eduardo Andrade, Priceline's Nita Drakatos and LRN's Denise Middleton.
Pictured are LRN’s Marsha Ershaghi, Priceline’s Eduardo Andrade, Priceline’s Nita Drakatos and LRN’s Denise Middleton.

Reflecting on Society of Corporate Compliance and Ethics’ 15th Annual Compliance & Ethics Institute, which wrapped up last week in Chicago, I had the privilege of moderating a panel discussion with our partner, The Priceline Group. The discussion centered around strategies to drive a high touch international ethics and compliance program strategy, with a distinct profile on The Priceline Group’s journey. Eduardo Andrade, SVP and Global Compliance & Ethics Officer, and Nita Drakatos, Compliance Manager, described their “Five Pillar Strategy” for reaching a global decentralized organization operating across its six distinct brands (priceline.com, Booking.com, KAYAK, agoda.com, rentalcars.com and OpenTable):

  1. Easy to Understand Global Policies
  2. In-Person Training with Interactive Elements
  3. Short, Relevant, and Engaging Online Training
  4. Awareness Tools, and
  5. Resources, including an Ethics Ambassador Program.

More corporate leaders are recognizing the impact of front-line management as influencers and core shepherds of organizational culture. Yet influence is not limited to positional management; it can also be driven through individuals that play an influential role as a nominated peer or champion of intentionally crafting corporate culture. Often these individuals are regarded as Ambassadors of the Ethics & Compliance initiative. Peer to peer influence is nothing new, and has deep roots in social learning theory, especially given how information transparency and technology platforms have given way to a vast amount of information. Compliance Officers are leveraging social influence through Ethics Ambassador programs to develop a more localized narrative that can help contextualize the program goals and objectives, opening the door to new voices, perspectives, and impact. In the case of The Priceline Group, given that 74% of its 17,000 employees are millennials, who are generally interested in working for organizations that do the right thing, Priceline’s Ethics Ambassador Program has been particularly influential. Here are highlights from our discussions:

Champions = Ethics Ambassadors, who are volunteers or sometimes are nominated or selected to help communicate with their peers about the E&C program, including the hotline, training courses, and new policies. At The Priceline Group, initially senior business leaders appointed the Ambassadors based on their character and leadership qualities in their location or role. Later, as the program messages grew virally, Ethics Ambassadors began to volunteer for the ambassadorship. Ambassadors have even been invited to play roles as avatars in the training modules.

Developing a Mature Cycle. Ethics Ambassador Programs can take time to develop, especially across multiple brands that are highly decentralized. For example, with The Priceline Group, they started with Booking.com and grew from there. They repurposed the objective yet allowed each brand to express itself through the program. Booking.com has 325 total Ethics Ambassadors in 64 countries with smaller yet expanding programs at Priceline’s other brands.

Communicate Often, Decision-Making Takes Practice. Ethical-decision making in today’s hyper-transparent global environment is not always clear-cut. Sometimes employees would rather make no decision than be held accountable for the wrong decision. Drive engagement by conversationalizing the Code of Conduct through local Ethics Ambassadors. These influencers can help drive more informal opportunities to simulate how ethical dilemmas can occur, identifying sample pressure points, provide guidance on perspectives, and contextualize how every day decision making impacts bottom line.

At LRN, we help organizations foster winning, ethical cultures rooted in sustainable values. Click here to learn more about our solutions.

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