The E&C Pulse - December 4th

December 4, 2018 Ben DiPietro

Diversity, Inclusion Intertwined With Ethics, Compliance

profile_pics_5profile_pics_6Catholic Relief Services, the official international humanitarian agency for the Catholic community in the United States, has for 75 years worked to help people who are suffering.

The Baltimore-based organization maintains development programs in the areas of emergency response, HIV, health, agriculture, education, microfinance and peacebuilding, and operates in more than 100 countries.

Sergey Hayrapetyan, the nonprofit’s global risk and compliance director, talks about what it means to be ethical versus being compliant, and why diversity and inclusion are necessary components of a strong ethics and compliance program.

Is it more important to act ethically or to be compliant?

Sergey Hayrapetyan: While there is a distinct difference between ethics and compliance--ethics traditionally being an internal behavior (doing the right thing) and compliance being external behavior (doing things right)--at Catholic Relief Services (CRS) we see ethics as both internal and external. Likewise with compliance.

To achieve our mission we accept resources from donors, including governments, under the terms and conditions that we agreed to comply with. Not living up to those expectations and/or not disclosing our compliance limitations is unethical. Integrity and honesty are the foundations of ethics and are the drivers for strong compliance at CRS.

When building our compliance programs we ensure that ethical aspects of compliance are well articulated and are part of the organizational communication, messaging and culture. In the past there have been instances when we found ourselves in a conflict with compliance activities not aligning with our mission, principles and/or ethical norms.

In such instances we either found workarounds and/or disclosed the limitations and inability to perform the requested activities due to the conflict. It is more important to act ethically than to be compliant, and it is not ethical not to disclose limitations and make informed choices.

How can organizations better embed ethics and compliance into everyday activities?

SH: By infusing ethics and compliance topics into agency behavioral competencies and/or guiding principles; through the natural integration of the requirements and standards in relevant activities; and through various types of organizational training and learning opportunities. This can be accomplished by immersing topics into required training provided to all staff, regardless of role or department, starting at onboarding.

At CRS, ethics and compliance is embedded into our agency behavioral competencies and our guiding principles. Behavioral competencies include integrity; building relationships; continuous improvement and innovation; accountability and stewardship; developing talent; and strategic mindset. The guiding principles are formed by the social nature of humanity; the sacredness and dignity of the human person; rights and responsibilities; stewardship; the common good; subsidiarity; option for the poor; and solidarity.

Similarly, during the onboarding process, staff are required to complete online learning modules that cover CRS’ behavioral competencies and guiding principles. These discuss ethics as a central component of CRS’ mission, programming and work. 

Is there an ethics and compliance case to be made for diversity and inclusion?

SH: Absolutely, they are interrelated and intertwined. Truly embracing diversity and inclusion requires one to operate from an ethical standpoint; conversely, operating from an ethical standpoint requires one to genuinely embrace diversity and inclusion. Diversity and inclusion in the workplace infuses a spectrum of perspectives, talents, backgrounds and work values that serve to enhance and refine the vision, mission, strategy and culture of the organization by augmenting, strengthening and making it more comprehensive. Given the type of work we do around the world, there is certainly a compliance case to be made for diversity and inclusion.

In implementing our programming on a global scale, we work to ensure that every one of our 7,000-plus staff members who represent/work for CRS...operates and conducts their work from a standpoint that honors and authentically embraces diversity and inclusion, recognizing the dignity and worth of every individual. Diversity and inclusion enriches and influences our seven pillars approach to performance, innovation, development and accountability, and is a driving force behind our compliance successes.

What can E&C do to gain more board influence?

SH: At CRS, we utilize effective escalation from the bottom up, and also semi-independent mechanisms such as councils, interdivisional working groups and other advisory bodies to reach executives and the board by using briefings, recommendations, and reports. The effectiveness of board engagement is attributed to clear problem statements, recommendations, proposed accountability through monitoring and reporting.  

How does digital transformation change the way E&C approaches employee and stakeholder engagement?

SH: The digital transformation and its fast progression continuously create opportunities to gain effectiveness and efficiencies at scale with all seven pillars of compliance. Because of these advancements we can effectively collaborate externally and internally in the development and iteration of the standards and procedures, their deployment, communication in various forms and shapes, and easy access while making our E&C ecosystem to be cost efficient.

The availability of real-time automated compliance data in smart compliance dashboards takes the oversight, reporting, auditing and monitoring to a whole other level, and pushes for more complementarity and transparency between those pillars. The creative digital media solutions, learning applications, interactive and communal learning platforms now take education and training to a progressive level and enable targeted, and adaptive learning. The mobile digital devices add mobility to the compliance infrastructure and put it in our hands, on our wrists, and in our ears.    

What are the opportunities and pitfalls as organizations adapt their programs for mobile?

SH: Looking through the lens of seven pillars, there are many opportunities and pitfalls. Some might be universal in nature, but many would depend on the industry, scope and scale of the program. For our industry, the mobile workforce gives us an opportunity to perform activities under all seven pillars faster, safer, cheaper and in a more transparent manner. The pitfall is in finding the right balance between the cost of enabling, maintaining and improving these opportunities versus the risks ethics and compliance programs are scoped to mitigate.


Ben DiPietro



A small-business survey by ComplyRight asked respondents how they keep up with labor law compliance issues: 69% said they rely on attorneys, accountants and business advisors, 78% said they wait for written notices from federal and state agencies, while 86% said they get their information from colleagues and friends.


U.S. regulators said companies that find problems in their legacy compliance systems when testing new technology won't necessarily be penalized, Samuel Rubenfeld of The Wall Street Journal reports.

The head of the Corporate Society of Compliance and Ethics, Gerry Zack, wrote on LinkedIn about the ethical questions that arise as companies apply more sophisticated data analytics to risk and compliance issues.

In response to #MeToo, some male executives on Wall Street are trying to limit if not eliminate instances where they are alone with a female colleague, but one employment lawyer says in this Bloomberg story these men are exposing themselves to sex discrimination lawsuits.

Farhad Manjoo writes in The New York Times that consumers need to become more aware of ethics in what technology they choose to use, and how they use it.

Getting an organization's chief executive on board with ethics and compliance is just the first step, Michael Volkov writes in his blog. 

A piece in Harvard Business Review looks at the risks managers face when they stop challenging good workers who no longer want to keep growing in their job.

We are in the midst of an insect apocalypse, and the risks to humans are significant, The New York Times reports.



Contribute to our annual E&C Effectiveness Report by completing this 15-minute E&C Effectiveness Survey. To show our appreciation, everyone who completes the survey by December 15, 2018 will receive a complimentary LRN training vignette about conflicts of interest. 



With the end of the year fast approaching,  we've compiled a roundup of our top resources for 2018 including reports, guides, case studies, thought leadership articles and webcast replays. Learn more about this year's top topics and trends.


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