Do you have a compliance and ethics program (CEP) that fails to address ethics? While we are particularly good at developing policies and training to help our business partners traverse the minefield of constantly changing laws and regulations, at times we can lose focus on the ethics component. Ethical decision-making is not synonymous with compliance with laws--it is bigger. Our own code of conduct is a testament to this point: Lawyers are expected to do the right thing even if the law permits different behavior.
Similarly, great companies are guided by values such as integrity and ethics. We have too many examples where corporate troubles ensued from a culture setting the behavioral expectation at compliance with laws (i.e., "As long as it's legal..."). As John C. Maxwell wrote in his book, There's No Such Thing As "Business" Ethics, ethical behavior cannot be inspired or even directed through legal compliance mandates. Maxwell asks: "Where can you find a standard that will work in every situation--a guide that will help you to sleep well at night, prosper in business, improve your marriage, and have confidence that you're doing all you can every time?" Maxwell's question compels focus upon the ethics aspects of our CEPs.
My company just transformed its CEP to deliver comprehensive training, including ethics training, and I thought I would share some lessons we learned along the way.
o The Code. Too often, codes of conduct are heavy on formalistic and complex policy and legal compliance statements, yet they are light on values and ethics. The problems with policy-based codes are that they are hard to understand (unless you have been through law school), and it is impossible for a code to envision the myriad scenarios faced by our business teams in the global business minefield. The gap between the policy and real life should be filled by the company's values. In our company, we reorganized our code around values and renamed it "Values in Action" to reflect the primacy of our corporate values and ethical standards.
o Ethics Training. How does one "train" an employee to act with integrity? Scores of companies and publications take on the subject of successful ethics training, but training alone does not create an ethical culture. Rather, ethics training should reflect the culture and reinforce it. If your company hires unethical employees or overlooks ethical lapses, your training program is not credible. Ethics training is not an event; it is delivered through observable and consistent leadership.
We recently conducted in-person training in order to reinforce our code and our values for employees. The daylong training course covered traditional compliance training as well as a module called "You Make The Call." In this section, attendees were given several scenarios raising ethical concerns. The scenarios were designed so that references to company policies would not resolve the issue; instead, corporate and personal ethics were called upon to address the scenarios. Individuals were asked to discuss with their peers how they would personally handle the matters presented.
The discussions were fascinating, as employees representing different functions, experiences and cultures shared unique perspectives. Resolving the scenarios compelled the trainees to reference corporate and personal values, and it reinforced the supremacy of "doing the right thing." The ethics training equipped the business teams with ethical decision-making paradigms that are more durable than any policy could be.