Is Your Ethical Culture on Auto-Pilot?

At the ECI’s Annual Impact Conference in Baltimore, LRN led a discussion with two eminent ethics officers on 10 practical ways to operationalize an ethics and compliance (E&C) program.

Too many programs rely on checklists and lists of rules, without focusing on how to impact business decisions in real time or the ethical choices that employees face in doing their work. The Department of Justice’s February 2017 criteria for program evaluation made clear that regulators are focused on what an E&C program does, rather than what it looks like on paper.

Kelley Edwards of Milliken & Company and Michelle Brown of Leidos shared their insights with me on these 10 practical measures for operationalizing compliance:

  1. Care about and sustain your culture:  it doesn’t work on auto-pilot;
  2. Deal with and address significant events such as a merger or the retirement of the company founder. These can have a profound impact on ethical culture;
  3. Use culture surveys to provide insight and a baseline;
  4. Increase impact by forming multi-function alliances throughout the company, such as Audit, HR, Finance;
  5. Involve everyone in the effort, not just the E&C function or legal team;
  6. Embrace constant improvement: benchmark, measure, and take results into account to ensure the E&C program stays current and relevant;
  7. Enhance the investigations function as a way to build trust:  use root cause analysis, summaries of results, and transparency to drive trust;
  8. Empower managers: use toolkits and specialized training to help them become comfortable having ethical conversations;
  9. Embrace innovative training/video and communications;
  10. Embed ethics and compliance considerations in performance management.

To learn more about ways to operationalize an effect E&C program, download our latest research report.

About the Author

Susan Divers

Experienced Ethics and Compliance Executive. Senior Advisor at LRN

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