MGM's Code of Conduct Journey: From Boring to Wow!
By BEN DIPIETRO
In 2013 it was apparent to everyone at MGM Resorts International Inc.--from senior management to the custodial staff--that the company's code of conduct was a dud.
"Everybody was bored with the old code...everybody was fed up," Omar Khoury, MGM's vice president of compliance, said Monday at the Society of Corporate Compliance and Ethics conference in Las Vegas. "Everyone dreaded that time of year" when they would have to take the annual code of conduct training.
MGM has a long-standing partnership with LRN, and it turned to the company when it was time to revamp its code.
Job one: Remove the legalese and make the code more readable and easy to understand while maintaining compliance with all the rules to which a heavily regulated gaming and entertainment company such as MGM must abide.
Job two: Link the code to add to the sizzle of the MGM brand, actively engage employees to participate in the new code, and make it accessible from anywhere.
Overcoming objections from the legal department to reforming the code can be one of the hardest challenges a compliance team faces when making the case to revive a stale one, but in MGM's case Khoury said there was full support from legal because it "had a good understanding of the importance of compliance."
For companies where legal is proving itself to be more of a challenge to win over, Khoury suggested being willing to compromise on what you are asking for, and for working to better educate the attorneys on the benefits that come from having a code that is readable, understandable and with which employees actively interact. That meant "reminding them not everyone has gone to law school," he said.
With legal on board, MGM worked to reduce the size of its code. The old version contained 92 slides that Khoury said people would just "click, click, click" on without really taking the time to engage with or understand what the company was trying to communicate to them. The updated code has about 40 slides and takes less than a half-hour to complete.
MGM then put employees in front of the camera, asking them what they thought of the code, about compliance and ethics in general, of what methods of reports they used to flag improper behavior.
"The feedback was amazing," Khoury said, as the changes brought the once-dull set of rules to life.
The company embedded into its code the links to the policies being referenced, and tied a portion of managers' and executives' bonuses to their satisfactory completion of the code training. If they didn't click on the links to the policies? The training didn't let them proceed until they did.
From left, Lisa Caserta, Omar Khoury and Marsha Ershaghi-Hames discussed how MGM Resorts International revitalized its code of conduct.
MGM focused on middle managers, which research shows have the biggest influence on an organization, said Marsha Ershaghi-Hames, an LRN Leader, who led the SCCE panel discussion.
The work involved creating an environment of trust and getting middle managers to be better listeners, so they could pick up on concerns being expressed by the people they were supervising, she said.
"Driving culture takes communication," said Ershaghi-Hames. It means "finding ways to stay connected all the time," in an time when people have multiple devices they are constantly checking. "But it needs to be a two-way conversation" that elicits feedback from employees and starts a dialogue with them.
The changes led to a 100% completion rate of the code training by managers, and MGM now is looking to offer incentives to the rest of its 77,000 employees to boost their participation rate closer to 100%, said Khoury.
The message of living the code is reinforced through the company's communications, said Lisa Caserta, MGM's director of compliance. Monthly newsletters contain compliance messages, and articles on topics including conflicts of interest, employee gaming policy, suspicious activity report reporting and the responsible serving of alcohol.
The goal, she said, is to maintain throughout the year the same level of engagement workers have with the code during the annual training.
MGM's next steps: Working on another code revision, before this new one gets too stale, said Khoury.
(Click here to read LRN's new white paper on how to bring your code of conduct to life.)