Compliance &Ethics - Society of Corporate Compliance and Ethics

FeatureAnalysisIn this second phase, analysis, the goal is toencourage employees to examine and identifypossible alternatives. This action is a selfexamination and is introspective by nature.The considerations include stakeholders whomay be affected or impacted by the decision.Perhaps the most poignant concern is the classic“headline test.” How would this employeefeel if their decision was made public, perhapsin the front page of their local newspaper?What would a reasonable person think aboutthis decision? How would they explain it totheir manager or family?In most cases, there are viable alternativesbased on stakeholder priorities. There may bemultiple considerations with varied outcomes.Employees need to examine each scenario anddetermine which option they believe wouldcause the least harm or greatest good.ImplementationArriving at a correct conclusion is futile withoutimplementation. It takes courage to takethe next step to do the right thing. Employeesneed to feel safe from retribution and retaliation.Written codes, policies, and proceduresare required and continued communicationsand training need to be in place to reinforcethese messages. Company messages shouldfoster an open door policy and encourageemployees to bring issues forward to theirmanagers, higher-level managers, EthicsOffice, Human Resources, Law departmentand/or company hotline.Developing the right modelIdentifying the appropriate questions andguide for your company’s model dependson the ethical culture and requirements ofyour organization. Northrop GrummanCorporation, a US-based global defenseBudget cuts—employees doingmore with lessPersonalconcerns overpay and bonusIncentive-basedcompensationFear of layoff orterminationIncreased pressureto achieve goalsInternalPressuresUnethicalBehaviorsIncreasedRisk-TakingExternalPressuresEconomicuncertaintyFigure 1: Northrop grumman’s Ethical Decision-Making Modelcontractor, uses a Just In Case (JIC) model forits 75,000 employees. This model was designedusing the JIC acronym for the Judgment,Introspection, and Courage phases of thedecision-making process. It is helpful to brandyour model with an easy to remember logoor visual depiction. In the case of NorthropGrumman Corporation, the ethical decisionmakingmodel surrounds the ethics valueslogo for the company.Customizing the model to your companyCompany cultures are varied and unique.Creating a successful ethical decision-makingmodel requires viable input from employeesand other stakeholders. In the case of theNorthrop Grumman model, focus groupswere conducted at various levels of theorganization to solicit feedback and determinelevels of commitment to using thistool. Originally, the JIC model’s phases wereJudgment, Intention, and Courage. Feedbackfrom employee focus groups suggested thateven the best of intentions may lead down thewrong path. Hence, the model was changedfrom Intention to Introspection.Rigid deadlinesand fasterturnaroundHigh nationalunemploymentBudget deficitsCost of livingindexCompliance & Ethics Professional May/June 2012+1 952 933 4977 or 888 277 4977 | www.corporatecompliance.org 41