In addition to the previously published seven elements of an effective compliance program, the 2004 review of Chapter 8 of the Federal Sentencing Guidelines emphasized the necessity of an ethical culture. The term “ethical culture” received widespread press over the years, but has been more recently replaced with the term “culture of compliance.” Without entering the debate about the difference between ethics and compliance, let’s explore one method of how to establish and sustain such a culture after the compliance policies, accountability, and communication are in place, and the “tone at the top” (meaning the CEO) is without reproach.
The method? Good storytelling.
More specifically, well-told, well-selected stories have the power to shape corporate culture because they give the listener to opportunity to feel with the hero’s story what it’s like to overcomes an ethical challenge or conflict and make the right choice. And it’s that feeling that can help guide future employee decision-making when facing new conflicts and challenges.
Here is one example of a true incident that was repeated many times, over many years and in many settings from new employee orientation to former employee reunions. At a company event a vendor was seriously injured as the result of an intentional act by the guest of an employee. The CEO was nearby and when he heard what was happening rushed over, gave another employee his personal credit card with directions to get the vendor to the hospital and pay for whatever care was needed on the CEO’s personal credit card. Did the CEO act according to an established policy? Don’t know, but it is unlikely that any corporate policy called for the use of CEO’s personal credit card. What is true is that employees learned the lesson from this oft-repeated story: When things go wrong, employees should step up and take responsibility, and take action.