Compliance &Ethics - Society of Corporate Compliance and Ethics

Compliance & Ethics Professional May/June 2013In addition to a representative sample ofleadership and the general employee population,I will typically interview all members ofthe Ethics Office staff and anyone responsiblefor developing and/or delivering ethics-relatedtraining within the organization.Document reviewThis is a bit more obvious than some of thequestions shown above. In assessing the ethicalculture of the organization, it is essentialto know what is “formally” stated as the standardsfor employee conduct. The documentreview also explores aspects of the organization’shistory, key decisions, and actions thatmay help explainsome of what theorganization is/doestoday. Typically, thisrequires a review of:··Relevant policies,procedures··Codes ofconduct/ethics··In-housenewsletters··Press releases,annual reports,and PR materials·· Summaries from previous company surveys,with an emphasis on any employeesatisfaction survey data··Website content—both “public” and “limitedaccess” (company confidential) content··New employee orientation materials··Ethics, management, and leadership trainingmaterials··Employee evaluation and salary administrationpolicies··Recent/pending union grievances (ifapplicable)··Legal and Ethics Office data regardingthe nature and frequency of internal andexternal cases with an “ethics” componentThe document reviewalso explores aspects ofthe organization’s history,key decisions, and actionsthat may help explain someof what the organizationis/does today.(which, by definition, is just about everycase that the corporate Legal departmentand the Ethics Office address)··Ethics Office call logs and case files··HR data regarding employee disciplinaryissues and patterns, including specific HRdisciplinary case files, as appropriateIt can also be useful to do a “Google”search of the company name and see what isbeing said, both by and about the organization.Other social media may also be explored,if deemed appropriate.Obviously, as an outsider, a consultantsuch as myself, must sign all the appropriatenon-disclosure agreementsand respect theproprietary nature ofthe specific cases.SurveysSurveys provideobjective data thatsupplement andinform the subjectivedata gathered throughinterviews, focusgroups, and documentreviews. When thatkind of data serves the client, I typically subcontractwith a specialty survey provider if acustom survey is called for, or use a standard,commercially available survey. In addition togathering client-specific data, I find surveyscan be invaluable in generating client datathat can then be evaluated against publishedindustry or national norms.My preferred source of data regardingthe generalized state of organizational ethicscomes from a series of reports published bythe Ethics Resource Center, which describesitself on their website (www.ethics.org) as“…a private, nonprofit organization devoted toindependent research and the advancement of60 www.corporatecompliance.org +1 952 933 4977 or 888 277 4977